NC0005011_Regional Office Historical File Pre 2018

date of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
Jame:3 B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
MEMORANDUM
To: Secretary Wayne McDevitt
From: A. Preston Howard, Jr., P.E.
Through: Linda. B. Rimer, Ph.D
Subject: CBP Resources Inc.
Date: November 4, 1997
This memo is in response to your request for information on the Department's actions regarding
odors being emitted from CBP Resources in Gaston County.
There are multiple sources of odors at this site. Odors have been attributed to CBP's increased
production rate, the installation of new processing components, raw material stored on site and the
wastewater ponds. These factors are confounded by prevailing weather conditions and the growth of
subdivisions near the facility.
To address these concerns, the Divisions of Air Quality and Water Quality have visited the site
many times in the past few months and have conducted joint inspections.
Odor control stipulations are included in CBP's state air permit; however, they only address
emissions of odors from t:he product manufacturing processes. Public comment will be sought on the draft
Title V penult later this year. The Permit will include increased monitoring and reporting frequencies. The
Division of Air Quality continues to inspect the facility and respond to complaints on a regular basis to
ensure that any odors emanating from the manufacturing processes at this facility are kept to a minimum
and that compliance with the Division of Air Quality regulations is maintained.
CBP's existing wastewater treatment process utilizes wastewater treatment ponds. Such ponds
normally do not produce strong odors when properly operated and maintained. When objectionable odors
are generated they are typically associated with an upset of the biological operation of the process.
However, even well operated wastewater treatment plants produce odors that some people may find
offensive. To the extent any odors are emanating from the wastewater treatment plant, we will attempt to
minimize those odors through intensive oversight of compliance at the wastewater treatment plant.
On September 5, 1997 the Division of Water Quality re -issued CBP's wastewater discharge permit
for a period not to exceed 18 months. The Division of Water Quality's intent is to improve water quality on
Crowders Creek through requiring connection to the City of Gastonia's Wastewater Treatment Plant. It is
my understanding that CBP is evaluating modifications to the treatment system in conjunction with the
requirement to connect to the City. During this process, the Division will be requiring CBP to examine
installing low odor wastewater treatment processes.
Additional information on this subject matter can be obtained by contacting Mr, Michael Landis,
Regional Supervisor, Division of Air Quality, or Mr. Rex Gleason, Regional Supervisor, Division of
Water Quality, at [phone].
cc: Alan Klimek
P.©. Box 29535, Raleigh, North Carolina 27626-0535
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NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
The Honorable lames S. Forrester
North Carolina Senate
State Legislative Building
Room 1 121
Raleigh,. North Carolina 27601-2808
Dear Senator Forrester:
This is in response to your letter dated August 27, 1997, in which you
requested information on the Department's action regarding odors being
emitted from CBP Resources in Gaston County.
Thank you for bringing this matter to my attention. The attached memo
from Mr. Preston Howard, director of the Division of Water Quality,
addresses your concerns.
Sincerely,
Wayne McDevitt
cc: Ann Case
Richard Rogers
Preston Howard
P.O. Box 27687, RALEIGH NC 27611.7687 / 512 NORTH SALISOURY STREET, RALEIGH NC 27604
PHONE [phone] FAX [phone] WWW.EHN6.5TATE.NC,USAEHNRt
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NORTH CAROLINA DE1"'ARTMET T OF
ENVIRONMENT AND NATURAL RESOURCES
The Honorable Herbert Kirsh
South Carolina House of Representatives
532 - A Blatt Building
Columbia, South Carolina 292.11.
Dear Representative Kirsh:
This is in response to your letter dated August 29, 1997, in which you
requested information on the Department's action regarding odors being
emitted from CBP Resources in Gaston County.
Thank you for bringing this matter to my attention, The attached memo
from Mr. Preston Howard, director of the Division of Water Quality,
addresses your concerns.
Sincere
Wayne McDevitt
cc: Ann Case
Richard Rogers
Preston Howard
P,O, Box 27687, RALEIGH NC 2.7611-7687/ 512 NORTH SALISBURY STREET, RALEIGH NC 27604
PHONE [phone] FAX [phone] WWW.EHNR,STATE,NC.US/EHNR/
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State of North Carolina
Department of Environment
and Natural Resources
James B, Hunt, Jr., Governor
Wayne McDevitt, Secretary
interoffice
MEMORANDU
To:
From: Lori Jones
Re: Correspondence
f2Zi97
Date:
Due Date:
Please review the attached correspondence and draft an appropriate response.
If the response is technical in nature, please send Secretary McDevitt a memorandum
(from appropriate division director/section head; through your respective Assistant
Secretary) explaining the facts. Then prepare a cover letter from Secretary McDevitt to
the constituent that acknowledges the correspondence but makes reference your
memorandum that we will attach. If the information isn't technical in nature, please
prepare a response for the Secretary's signature and return it to your Assistant
Secretary. Return the response in the blue folder along with the original letter to your
Assistant Secretary.
Prepare necessary envelopes (include envelopes for cc's). If attachments art to be
included, make appropriate copies for addressees and cc's. The original letters will be
mailed from the Secretary's Office and a copy will be returned to you for your files.
As a reminder; please copy Richard. Rogers on all responses to legislators and local
government officials.
If you have any questions; please call me (919) 715 1 V.
P.C. 60x 76 37, Raleigh, North Carolina 27611.76e7 Telephone; 919.733.4984
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DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF AIR QUALITY
MOORESVILLE REGIONAL OFFICE
September 10, 1997
MEMORANDUM TO: Alan Klimek
FROM:
THROUGH:
SUBJECT:
Ronald E. Slack
Michael S. Landis
Reply to Senator Jaynes Forrester
Attached is a draft response to the request for information sent by Senator Forrester on
August 27, 1997.
CBP was recently given 18 months to complete their connection with the Crowders Creek
Wastewater Treatment Plant across the street from them. They plan on building a pretreatment
building and continue using the lagoons. How much this will reduce the odors is unknown.
Odor complaints by Dorco Manufacturing (/ mile north) at 0810 hours on August 27
resulted in a surveillance that started about 0930 hours. 1 only observed a faint (level 1) odor on
the road by the plant site, and the lagoon had level 2 odors next to it,. Dorco only complained in
the past when there were process odors, so 1 suspect that the plant still has some periodic problems
with process odors. On August 22, Tony McManus observed level 3 lagoon odors about '/z mile
south of the plant. We continue to believe that the majority of the odors come from the lagoons.
C \SECRE1'AR',S'ENATORAW

SENAT IF1 DAMES FORRESTER
39TH D!STRICT
GASTON-FREpELL•LiNCOLN
OFFICE ADDRESS:
TELEPHONE:
HOME ADDRESS:
HOME TELEPHONE:
OFFICE TELEPHONEr.
ROOM 1121
RALEIGH,. NC, 27601-2808
[phone]
[phone] FAX
P 0. 80x 459
STANCE'. N.C. 28164
[phone]
[phone]
August 27, 1997
The Honorable Wayne McDevitt
Secretary
Department of Environment, Health and Natural Resources
512 Salisbury Street
Raleigh, NC 27604
Dear Secretary McDevitt:
COMMITTEES,
APPROPRIATIONS/BASE it UDGET
VICE'C-HAIR
APPROPRIATIONS ON HUMAN RESOURCES
RANKING MINORITY MEMBER -
CHILDREN AND HUMAN RESOURCES
RANKING MINORITY MENDER
RULES a OPERATIONS OF' THE: SENATE.
RANKING MINORITY MEMBER
COMMERCE
EDUCATION/HIGHER EDUCATION
JUDICIARY
I arr3 enclosing correspondence which I received from a constituent in Gastonia,
Delilah R. Brandon, which refers to unhealthy air quality around her home and her
unsuccessful efforts to have North Carolina Environmental Officials in Mooresville
correct the problem.
I would appreciate your looking into the matter and letting me hear from you.
JSF/rnj
Enclosure

The Bonorable Berbera Kirsh
P. O. Box 31
Glover, SC 297
Dear Representative hash.
2593 Forbes load
Gastonia, N. C. 28056
,august 21, 1997
I wanted to express my thanks to you for your interest in our
air quality in the area in which I live. When I left any home
COMR to work today 1 could not breathe anything; but "stink".
I have made many efforts to ask the worth Carolina Environmental
Officials in Mooresville to please do something. They were always
interested and assured me that C p was "going to installs" esteltment
to eliminate our Problem,.
can say today that It is no better. I have one grandson that has
asthma..,. I feel that this type of a quality is not a good thing for
him to hive with and I am concerned for him.
feel sfortunate that we have people life you and out o state senator
Forrester, whom I have always supported, take an interest in this
orn out" issue. Thanks main. :for any relief you are able to secure
for this area -
'he Honorable Tim Forrester
1104 Stanley -Lucia Road
anley, NC 28164
to Dr._ Forte ex.:
Sin
Delilah.
Brandon
y personal thanks to •you for any effort you tame in
dealing with our problem.
Sincerely,

UUl V, LL. K U 5eH
NORTH C
0
RESVILLE
Xt-liret
IC 2E13.5
pie 704/663-1699
FAX
A
0
OF
/Ai 704/663-5D40

DEHNR MODRESVILLE R 0
sep lo l./.2
likrbert Kirin
District No. 47 - York County
Home Address:
Box 31
Clover, SC 29710
Bus. [phone]
Res. [phone]
Columbia Address:
532-A Blatt Building
Columbia, SC 29211
-fa [phone]
Mr. Rex Gleason
Regional Supervisor
Division of Water Quality
DEHNR
919 North Main Street
Moorseville, NC 28116
Dear Mr, Gleason:
uuse Pfgepresenta
)11ltat* Pf 1d11 eSrailia
•
August 29, 1997
grivtR014/45314
&
SEP 0 5 1997
Committees:
Labor, Commerce and Industry
Business and Commerce
Sub -Committee
Insurance Sub-Cormu Arra
York County Legislative
Delegation, 'Secretary
Education Improvement Act
Select Committee, Vice Chairman
State Reorganization Commission,
Vice Chairman
Local Government Study Committee
I have received a letter from Mr. Michael Landis in response to a letter I wrote
to him on August 14, 1997 regarding the continuing odors being emitted from CBP
Resources, Gastonia, Gaston County, North Carolina.
Mr. Landis and his cohorts assure me that the overwhelming majority of the
odors continue to emanate from the waste water treatment pond. Mr. Landis has
talked with the Division of Air Quality Director and Deputy Director and all three agree
that there is little they can do because these odors are characteristic of this type of
waste water and treatment system, (a copy of Mr. Landis' letter is enclosed).
Mr. Gleason, If this Is characteristic of this system, then you need to make
some changes. There are probably several thousand people or more, who are being
affected by these odors. This has been going on for many, many years, and the
people of both states are really getting sick and tired of this situation. In my view, 1
cannot understand why this problem has not been corrected. Surely, there is
technology today that can handle it. Haw long do citizens have to put up with an
odor that is nauseating and sickening?
I am requesting that you and your department. (and Mr. Landis), work on this
situation immediately. There have already been too many years of delay. The citizens
near this plant have lost property value and many are suffering from health problems
because of one simple fact - no action on the part of DEFINR.

DEHNR MOORESVTIti(..E R 0
Sep 3 '9? 1.:31 P.03
Page Two
August 29, 1997
Once again, 1 seek relief for my constituents and neighbors in Gaston County,
who reside in the vicinity of this plant.
Action, please!
Sincerely,
HK "ffclag29-1,2
cc: The Honorable ©avid M. Be ay, Governor, State of South Carolina,
Post Office Box 11369, Columbia, SC 29211
The Honorable Doug Bryant, Commissioner, SC Department of Health
and Environmental Control, J. Marian Sims Bldg. And R. J. Aycock Bldg.,
2600 Bull Street, Columbia, SC 29201
The Honorable James Hunt, Governor, State of North Carolina, State Capital,
Raleigh, NC 27602
Mr. Fred M. Taylor, Post Office Box 856, Clover. SC 29710
Mr. Robert Huffstetler, Post Office Box 1395, Gastonia, NO 28053
Mr. Ken Love, 1491 Lova Road, Clover, SC 29710
Mr_ and Mrs. Jim Andrews, 1089 Greenpond Road, Clover, SC 29710
Mr. Stephen D, Spigner, Catawba District Environmental Control, Past
Office Box '1 00, Fort Lawn, SC 29714
The Reverend and Mrs. Bob Abel, 251 Ridge Road, Bowling Green, SC 29703
Mr, Richard Penegar, 737 Ferguson Ridge Road, Gastonia, NC 28052
Mr. Frank Boyd, 195 Rainbow Circle, Clover, SC 29710
Mrs, Dean Miller, 950 Barnett Road. Clover, SC 29710
Mrs, Delilah R. Brandon, 2593 Forbes Road, Gastonia, NC 28056
Mr. Jeff Glenn, 1122 Hidden Brook Lane, Clover, SC 29710
Mr, Jim Lovell, 952 Brandon Road. Clover. SC 29710
Mr. Steve Leer,Gaston Gazette, 2500 E. Franklin Ave., Gastonia, NC 28053
The Honorable W. W. 1Dubl Dixon, 718 Avondale Road, Gastonia, NC 28054
The Honorable John R. Gnrnbel, Jr., PO Box 250, Lincolnton, NC 28093
The Honorable Joe Kiser, PO Box 47, Vale, NC 28168
The Honorable Debbie Clary, Box 2266, Shelby, NC 28151
The Honorable John Reyfield, 119 Oak Trail, Belmont, NC 28012
The Honorable Sherrie. K, Berry, 1400 S. College Blvd., Newton, NC 28658
The Honorable John J. (Jack) Hunt,. Box 277, Lattimore, NC 28099
The Honorable John H. Wea'therly, 142 Quail Hollow Drive, Kings Mountain. NC 28'086
The Honorable David Howie, 604 Queens Drive, Dallas, NC 28034
Tha Honorable Jim Forrester, PO Box 459, Stanley, NC 28164
Ms Kitty Wynnberry, 4800 Maple Leaf Lane, Gastonia, NC 28056

ULHNK NLUKt5V1LLL K U
Sep .5
P. 04
State of North Carolina
©eoartment of Environment,
Health and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr,. Governor
DIVISION 0P Al QO
August 24, 1997
The Honorable Herbert Kirsh
House of Representatives
State of South Carolina
Post Office. Box 31
Clover South Carolina 29710
Subject Odors fro nxt CBP Less urc
Gastonia, North Carolina
Gaston County
03/36100026
Permit No,
Dear Representative Kirsh:
This letter is in response to your letter dated ,August 14, 1997, in which you requested that
this Office provide further information regarding odors beingOfesourcesfice did no,
Gastonia, Gaston County, North Carolina. In your letter, you stated that this
rt
esp©rnd to your letter dated April 1, 1997, with regards dated April
as 1 n199? and ane issue. utlined below is t
update of current
explanation for our lack of response to your letter
activities regarding CBP ResourceS.
In our March 18, 1997 letter to you, this Office indicated t t1 twrisieari of
had determined that the odors emitted from CBP Resourceswere emana letter,e indicated to the
wtl a water
ater
treatment ponds located on the plants property. In that
quality staff of this office determined that the odorsfrom
deficiencies, ee ter also treatment ponds
based on
were not
being caused by improper maintenance or operationalthe odors appeared, to be characteristic odors
the water quality staff''s experience with this facility,
associated with this type of wastewater and treatment no chimes in our letter
I hid
e
within three weeks of the first letter and there had beenyou would ward
nothing new to add to what I bad originally submitted to you, and 1 did
997 letter you twouldd this
to read the same information again, Additionally, in your April 1,
Office for our response to your March 10, 1997 letter to this Office with regards to odors from
919 Nprtfit Mein Street
Mooresvile, North Cora!inv 26116
Voice 7: *53-1a49
N C
FAX [phone]
An Equal apportunity/Atftrmntive Action Etnp►oy
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DEHNR DJRE ERO 0
Sep 3 '97 16.32
P. 05
tteprcaenutive Hated ICarsh
Augua 20, 1997
Page 2
CBP Resources. Therefor 1 did not believe a response was necessaryat that time. I apologize
for this misunderstanding, 'ie c be assured that I will respond to each letter that you send to the
Air Quality Division in the fut rc.
u vrt CBP' Resources: The 'Division of Air Quality has gone by
The fnllcnwung is t+a update 'yv ciiity many times in the past few months. The overwhelming majority of the odors continue
d with the
of
ua
anate from the wastewater treatsnent ponds. 1 havethat
longas the waster of Aix tQ mcnt
or and Deputy Director, and we all three agree permit
ponds are pioperly operated and maintained in accordance with the waste tedo about and
compiles with the limits in that permit. trheatmerTt pngdsre is little �siDtt� Division
according Quality
Division of Water
the
odors emanating from the west � wastewater and treatment system. The
Quality, these odors are ityc�cttnstic ©f this type,.a : �o� � v comp � �� a on a r+a� , =,
basis
u Air thatQuany from the manufacturing process= at thie facility are kept
basis to ensure any odors emanating
to a tninursunn and that compliance with the Division of Air Quality regulations la maintained.
If you have any questions with reference to this matter or require further information, please
do not hesitate to contact W. Ron Slack or me at [phone]. If you have any questions with
reference to the operation of the wastewater treatment ponds., please contact Mr. Rem Gleason,
R.egioaal Supervisor, Division of Water Quality at [phone].
Re Iona! Supervisor
MSL`s
c: Alan l 1i�k
Centr
G'A6MOLTWFD6TA ttxtzcs\Gasrc7

DEHNR ESV I .E R 0 Sep 3 '9? 16:32
From: Self aNROAROS!T 19W29>
To: cP.IPMAILMEMWQ.PML
Subject: Rendering Essence in Southern Gaston County UMMMMI
Copies to: NROARa5IN1 EA7p3, ,NROARg51NiEA334
Date sent: Fri, 21 Feb 1997 11:16:48 +W OO ET
WQ Staff,
Some of you are aware of the alleged malodorous situation existing
at/near the Carolina By-products (CBP) facility in southern Gaston
County. The CBP rendering plant has been operating at its present
location for as long as I can remember, and I've never known the
facility not to stink! The facility's wastewater treatment primarily
consists of a series of lagoons, one of which contains an area that
is curtained off where mechanical aerators provide concentrated
aeration. This treatment scheme has been in use for a long time, and
generally has done an acceptable job of treating the wastewater. as
far as permit compliance is concerned. I've only known two times
that the WQ section has recomended enforcement. One was for a breach
of a sludge lagoon, which resulted in a fish kill; the other, and
most recent, was for permit limits violations. The Company paid the
full penalty for the first case. The second case is still pending.
I attribute the increasing number of complaint calls to the ever
increasing residential develo ment occurin around the lant...Not
because t e plant or its wastewater treatment feel ities are any Tess
effective/efficient or are any more stinkin' than they've always
been. Regardless, we still have to deal with the complaints.
Therefore,. I am asking Trish and John to work closely with the folks
in AQ (probably Ron Slack, Tony Mc., and, particularly,Mike L) so
that this office can come up with an appropriate response to the
complaints. Personally. I don't think we'll ever resolve the
question of whether the odors are solely attributed to AQ or WQ. l
also don't think that really should be the Issue. The important
thing is that both WO and AQ conduct joint investigations to
evaluate the effectiveness of the pollution abatement facilities- at
CBP, and assure ourselves that the Company is operating the
facilities in accordance with appropriate standards and in compliance
with EMC rules. Once we are convinced that the Company is
operating/maintaining the facilities In accordance with our
respective criteria, and we are satisfied that no laws or EMC rules
are being violated, then we have solid ground to so advise the
complainants. It should be noted (and I'm sure this is the case with
some air pollution control devices) that odors are emitted during the
Gleason, Rex
Wed, 3 Sep 1997 14:12:46

DEHNR P iRESVILLE R 0 Sep 3 '97 16:33 P.07
treatment of most wastewaters. Usually the odors are characteristic
of the type of wastewater being treated and the type of treament
being used. Although the use of lagoons as a means of treatment may
seem outdated, they are effective in treating the type of wastewater
generated by CBP. This state, the industry, and the feds all agree.
Therefore, until there are new laws, rules, regs, or guidelines we
will continue to enforce existing legislation and also continue
business as usual. Please excuse the above ramblin', as most of you
in WQ are not concerned with this matter, BUT in the event you get a
call from anyone re, odors at or around CBP, please refer the matter
to Trish, John, or me. Best not to attemp to explain the situation,
unless you're really familiar with recent activities, AND please do
not imply that the odors are AQ related and therefore the caller
needs to talk to someone in AQ_ I'm sure we can count on AQ staff to
do likewise.
To summarize, from this point on AO and WO will conduct joint
investigations of all citizen complaints related to odors. Each
section will evaluate pollution abatement facilities/devices that
they permit/regulate, and assure that the Company is operating and
maintaining such facilities in accordance with Divisional
requirements. Once we have this assurance, our response to the
citizens will be singular (hopefully) and consistent, and then maybe
we can return to our routine inspection activities.
I'm hopeful all are in agreement with this approach. If
not, at least its open for discussion.
Rex
Gleason, Rex
Wed, 3 Sep 1997 14: "l 2:46

Alien Jernigan
ntal Division
919) 716-6600
[phone]
4.4.4t
Mr. Richard Penegar
O.G. Penegar Company, Inc.
P.O. Box 839
Gastonia, N.C. 28053
11.21i ii?'t' ';'r"-*
JTV
RE: CBP Resources' Gaston County Chicken Processing Facility
Dear Mr. Penegar:
Your letter dated September 8, 1997, to Attorney General Michael F. Easley concerning
CBP ResourcesGaston County facility has been referred to me for response. The Attorney
General thanks you for your letter and appreciates your concern over continuing water quality
and odor problems arising from CBP's rendering operation.
Last year, the Division of Air Quality of the Department of Environment and Natural
Resources (DENR) levied approximately $15,000.00 in civil penalties against CBP for
violations of state air quality laws. In response to the Division's penalty assessment, CBP
entered a Special Order By Consent, effective December 13, 1996. As an initial matter, the
Special Order required that CBP pay $28,000.00 in settlement of all noticed violations of state
visible emission and odor laws. The Special Order further required CBP to construct and install
a biofilter designed to reduce odors from the feather cooking process by 75 to 95%. Through the
Special Order and subsequent air permit modifications, the Division of Air Quality has also
imposed several operational requirements upon CBP to further control odors, including the
construction and operation of a separate blood processing plant and a pound weekly
limit on the amount of feathers and blood processed.
We have been working with DNER to determine whether technical data demonstrates
violations of State water or air quality standards at the facility sufficient to warrant additional
legal action. Presently, DENR has not referred this facility to our office for initiation of a civil
action for injunctive relief to restrain the operation. I have been advised that DENR is reviewing
this situation and others where odor and water quality concerns appear directly interrelated.

September 24, 1997
Page
Your attached letter of SepteSeptember 8, 1997 Mr, Kirsch also inquired about the status of
CBP's pending mater quality permit modification application. It is my ders ding that the
application is still pending. By copy of this letter, I . referring your concerns d questions to
Mr. Preston Hoard, Director, N.C. Division of Water Quality and Mr. Alan Klimek, mek, Director,
N.C. Division of Air Quality for further investigation and a more detailed response, as they
the responsible permitting agencies.
If you have er questions about this facility, please feel free to contact me.
Very t 1y yours,
J. Allen ei
Special Dep
cc. Preston Howard, Director, Division ofWater Quality
Alan Klimek, Director, Division of Air Quality
eneral

Interior Design Space Planning Office Furniture Systems
O. G. Penegar Company, Inc.
P0. Box 839 • Gastonia, NC 28053
704/865-1236 375-5586
September 8, 1997
SEP 1 2 199/
N.C. ATTORNEY GENERAL
Environmental Division
Mr, Mike Easley, Attorney General
PO Box 629
Raleigh, NC 27602
Dear Mr. Easley,
'1V7i7q a7014f4A—
C:.;:-i. OF ATTORNEY GENERAL
RECEIVE.D
Congratulations are due to you and your and staff for taking
the time and making the effort to do something for all North
Carolinians - closing the Purvis hog operation in Montgomery
County. There is no need to tell you all the good reasons,
certainly this action sends a statement that your office is not
going to tolerate such abuses to our rivers and streams.
The reason for getting in touch with you at this time is to
ask you to do the same thing for this part of the state. Our
problem is not swine lagoons but chicken entrail lagoons polluting
water and air quality in Gaston County.
Enclosed is the letter I have sent today to Herbert Kirsh who
has come to our assistance from the South Carolina side. The
people in his county and much of the piedmont of South Carolina are
also effected by this constant pollution.
I hope you can ask someone in your department to give some
attention to this matter. Enough is enough, 20 years and it still
goes on. If there is any way we may assist you please feel free to
call.
Sincerely,

Interior Design Space Planning Office Furniture Systems
O. &. Penegar Company, Inc.
P,O. Box 839 • Gastonia, NC 28053
704/865-1236 375-5586
September 8, 1997
Mr. Herbert Kirsh
House of Representatives of SC
Box 31
Clover, SC 29710
Dear Mr. Kirsh,
Thank you for copying me and others with your letters, to DEHNR
in your efforts to clean up the air and water pollution at the CBP
location near our homes. I wish you well in your endeavor.
In one of your letters you mention that this problem has been
going on for 10 years. As a matter of fact we have been patiently
trying to correct the problem with CBP and its predecessor
corporations by talking with them and talking with the Regional as
well as the NC State Department of Environment Health and Natural
Resources for over 20, vears - to no avail.
There is technology Mr. Kirsh, to correct this problem. A
good corporate citizens and a truly concerned State Agency would
spend the money to do it. Mr. Landis is less than truthful when he
tells you in his letter to you of August 29th when he says these
odors are characteristic of this type of treatment system. He
fails to tell you that other States use different ways of doing it
and thus eliminate the odor. He also fails to tell you about the
uncovered, untaxed trucks parked in the hot sun for hours waiting
to be unloaded. He also fails to tell you that because of the
expense of running the scrubbers they frequently cut them off
especially on the weekend when they know it will be difficult to be
reported. The law requires these people to run the scrubbers all
the time, but; "the State doesn't have enough people" to inspect
them everytime they turn off the air scrubbers, is frequently
DE}NR's excuse.
Recently (June 12) there was a hearing in Gastonia on CBP's
request for a permit to increase their pollution into the creek,
ninety-nine percent of the opinion expressed at this hearing was
adamantly negative to renewing of the permit let alone increasing
it. Enclosed is a copy of my remarks at the hearing. You can see
the frustration of broken promises not only from CBP but from the
DEHNR. We have had no word from DEHNR in the 3 months since the
hearing!

Interior Design Space Planning Office Furniture Systems
O. G, Penegar Company, Inc.
P.Q. Box 839 • Gastonia, NC 28053
7041865-12.36 375-5586
By copy of this letter I am informing the State of NC of our
continuing concerns and also the Attorney General asking him to
close this plant down as he was able to do with the hog operation
in Montgomery County - until it can meet State standards. There is
no excuse for this operation to continue to promise and never
fulfill its obligation to the citizens of our state and yours!
Let me thank you again and also offer to you the services of
the residents of the Crowders Creek area in any way that can help
our common cause.
CC:
ke Easley, Attorney General
David Hoyle, Member NC Senate
Jim Forrester, Member NC Senate
John Gamble, NC House Representatives
Dub Dickson, NC House Representatives
David Cline, Chairman Gaston County Commissioners
Steven Bryant, Aide to Governor Hunt

Wastewater in Crowders Creek
Stop the dumping, plart officials told
By Melissa Manware
The Herald
GASTONLA N.C. — One of the few things
people attending a water quality hearing
'Thursday agreed on is that a North Carolina
chicken processing plant needs to stop
dumping its wastewater into Crowders
Creek.
The hearing, held by the N.C. Department
of Environment, Health and Natural
Resources division of water quality, was to
ktiublic comment on CBP Resources'
40*e 'st to renew its permit to drain waste -
water into the creek. CBP ako wanted to
increase the amount of water it dumps.
The hearing was at a junior high school
in Gastonia.
York County residents who live in the
Bowling Green community have complained
for years that the rendering plant produces
a nauseating stench and is polluting the
water which eventually runs into Lake
"I can't get away from the stink," said
Jeanne Foguth, who lives near the plant.
"The stink comes from the water. We can't
please see HEARING, back page
•
014
Hearing
from IA
eat on our back deck. We can bare-
ly eat inside."
Tielpivision. of Water Quality has
'tentatively recommended approving
the permit, but not allowing CBP to
dump more wastewater and requir-
ing it to hook on to Gastonia's waste-
water treatment plant within two
years..
Don Carmichael, Gastonia's direc-
tor of public works and utilities, said
CBP Resources has signed a letter
of intent to connect with. the city sys-
tem. Five CBP representatives were
at the hearing, but none of them
spoke.
Tom Burton, a York County
Councilman., said the agreement was
a step in the right direction, but the
council thinks CBP shouldn't be
allowed two years to rnake the tran-
sition.
Marcus Norton, the York County
planner, said one year should suf-
fce.
Others snit] the issue shouldn't:be.
- how long the rendering plant has to
comply. They want it shut down.
"... Understand thatthe coeduct:
of the applicant over its entire his-
tory at this plant has been 3 censtaitt
story of delays and postponements,.
of promises made and promises bro-
ken," said Richard Penegar, who 1
lives along Crowders Creek.
CEP violated its permit 22 times
between July 1995 and June 1996,
according to state records.
Bobby Bowe, 'who conducted the
healing, said sending the wastewater
to the city plant would eliminate any
odors coming from the water. He
said, hoveever, he didn't know how
ITILICT, et:the odor came from the
water..
Blowe asked the audience to save
their comments about the smell for
an air quality meeting, which he
promised would be held later this
rear,. several peop!e ii,vho had signed
up to spez,k passed \\then their turn
came, but said they will be back to
address the pungent odor.
the healing, Mel. Roshanrayan,
vice :resident of the environment
for CBP Resources, admitted there
are ''cdors associated" with the chick-
en rendering process.
"Vaat we d.o is a lreniendous ser-
vice. ;r,al.ze valuable products
ni what would otherwise go to
landfills' he said, ndding that in
order to clean the air properly. the
company needs to produce more
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he Herald s:.aff ple

Easley wants 1'y1iige hog farm closed
BY JAti',E5 ELS SHIFTER
Attorney General Mike Easley
asked a judge Thursday to shutdown
a Montgom ry Col .ala' hog farm
because a :May 27 waste spill killed
hundreds of fish in a nearby creek
The Riverside Farm, operated by
N.G. Purvis Farms Inc. of Carthage,.
has a three-year history of tangles
with state environmental regula-
ors aver its handling of swine
ewage. A waste spill in 1994 first
drew the state's attention to the
ina and inspectors discovered the
year that sludge from the
arm's. waste lagoons was running
off a hillside into a stream, said
Tommy Stevens, the state Division
f Water Quality's regional super-
'isor in Fayettev111e.
In Fehruary, Purvis Farms paid a
$5,000 fine and promised in a court
settlement to abide by a state -
approved waste -disposal plan,
Stevens said.
But on May 27, 3,000 to -1,000 gal-
lons of hog waste gushed out of a
hole in a pipe at Riverside Farm.
Stevens said officials found 800 to
1,000 fish floating in nearby Dison's
Creek,
Only after inspectors arrived did
the farm's operators try to pump
some of the waste out of the creek,
Stevens said.
"The rupture of the pipe is bad.
enough, but the failure to act imme-
diately to correct the problem and
prevent environmental damage is
intolerable," Easley said in a state-
ment. "State agencies have tried to
work with Purvis in the past, but
they simply refuse to act responsi-
bly. These people need to he shut
down, for good."
N.G. Purvis Farms operates nine
hog farms in Chatham. Richmond,
Montgomery and Moore counties,
said its treasurer, Jerry Purvis, The
company's recent eiiors to expand
in Chatham and Moore counties
have brought opposition.
In response to Easley's effort to
get his farm declared a public nui-
sance, Purvis replied: "Mike Easley
is a public nuisance."
A court hearing on the closure
motion is scheduled for June 13 in
Randolph County
Domes Eli Shifter con Ise reached
0i B36.5701 or [e-mail];n

June 12, 1997
To Secretary Jonathan Howes and hi/i appointed representation
holding this meeting.
Comments and Testimony on CEP Resources Application to Renew Permit
for RENDERING in Gaston County, NC and to increase their daily
discharge from 270,000 gallons per day to 350,000 gallons per day.
My name is Richard Penegar, a resident and business owner
in Gaston County for over 50 years and a resident of
Crowders Creek - 1 mile west of the CEP plant for 21 years.
Thanks for allowing me the opportunity to make these
comments to the Department. Mr. Chairman here are my 3
copies of the prepared remarks as well as a copy of the
Gaston County Commissions Unanimous Resolution opposing this
permit, and the Commissions strong support of
public in part from individual citizens and the various
groups like the Lake Wylie Marine Commission, the CCEC,
and other water and air quality community action groups
from Gaston, York and Mecklenberg Counties who are also
victims of the Applicant's gross disregard for the.
responsibilities and obligations incumbant under this
permit.
Also enclosed are several tax filing documents of the
Applicant which I hope you view as appropriate reflection
of the Applicant responsibility. It will show an additional
expenditure of over $500,000 in 1996 of expansion recycling
type of equipment (with no apparent improvement in the
pollution they are causing) and a total of $3,000,000 on
which they did not pay one cent of taxes to Gaston County.
This does not include any of the multi -million dollar fleet
of vehicles, tractors, trailers and the like on which they
also do not pay any property tax as they roll across the
roads of North and South. Carolina.
My purpose here tonight is to offer some insight from the
public's point of view that will allow you people, the
Stewards, the Guardians of our Enviroment in NC - to take
action that will benefit the victims of your past action
and mistakes in dealing with this Company and their
practices at this plant in Gaston County.
You have already heard and will hear more tonight regarding
the horror of the fish kills and nauseating odors that
continually permeate the air for miles around the plant.

Since
been s
he early 90's these odors are the worst they have
nce 1976.
The pollution of our streams and rivers is bad enough all
over NC but I suggest to you that this stream, Crowders
Creek and this river, the Catawba, is just as important and
just as endangered as the Neuse and serves a vital, albiet
politically under represented, part of the state. Do we
need a Dr. Burkholder to get your attention?
I think not, what we first need to do is to get you to see
and understand that the conduct of the Applicant over its
entire history at this plant has been a constant story of
delays and postponements of promises made and promises
broken. Like the Tobacco Industries blantant denial of the
addiction of Nicotine, CBP insists through its actions that
a little amonia in the drinking water never hurt anybody
and that they don't smell anything obnoxious in the odors
thet produce.
What needs to be done, gentlemen, is first thing. Deny the
request for the increase in the discharge. Period.
Next, if you're not totally convinced that the permit
should be revoked pernently you should give them no more
than a temporary permit - 90 days at the most to work out
a satisfactory agreement - satisfactory to you, Gaston
County and a local Citizens Committee, with the City of
Gastonia to handle all of the Waste Discharge from plant.
As a condition to the temporary permit CBP should be
required to post a minimum bond of $1, ©0©, 000 forfitted to
the State for failure to complete the work required within
one year from the date of agreement and a fine in the same
amount if the work is not completed within 6 months from
the date and full withdrawal of all permits to them or
succesors corporations for operating at this location
forever. Let them go to another creek nearer the center of
their customer base and start messing up someone else's
neighborhood.
The Applicant has lied to you and the people of NC too long
You have been misled - perhaps you have been too lax in
inforcing the Regulations of the State.
If someone lies to you once or twice it's nobody's fault
but if you believe their broken promises over and over for
20 years you are as much the guilty party as they are. Your
commission is culpable in the victimization of the
citizens of this State as well as our neighbors in SC. And
you are responsible for bringing about a solution that stops
this pollution.
erely,

-16 Revised 9/19/95 G:\DEM\AQ\WPDATA\COUNTIES\GASTO
NORTH CAROLINA DIVISION OF ENVIRONMENTAL MANAGEMENT
26 t970122A,C16
Name
CBP Resources
Contact
Type Action: CI X EE
Air Program Status:
Action Requested By:
Last Insp. Date 6/24/96
Air Quality Action Report
Location
Gastonia, Gaston County
Telephone
Other: Surveillance
Class: A. e to: ___
Address/Phone
Action Date 1/22/97
Permit # 3590R13 Issued 9/19/96
Data Tracking: LI EMS LI ITS 0 TOXLB El COMPLAIN 0 I -STEPS Action Number:
Recommendations: Signature:
Continue Surveillance Barry Addertion
Reg/Co. /Prem.No.
03/36/00026
Rectd Date
Next Insp. Date Ongoing
Surveillance
Expires 6/30/97
7
This facility is a rendering plant that mostly processes chicken blood and feathersas raw' material for dog food
manufacturers. It is located approximately one mile north of the NC/SC state line on Highway 321(5533 South York
Road) in southern Gaston County, North Carolina.
Date:
I received a total of eight (8) complaints about odors from CBP for the week of 18-24 January 1997. Three (3) of the
complainants only left their name with the receptionist at MRO. Mr Ronald Slack also handled several complaints during
this week. It should be noted that information has been placed in mail boxes requesting people to call MRO about the
smell.
Jaguar), 22, 1997
I was accompanied on a visit to the facility by Mr. Ronald Slack. A report on the visit has been written by Mr. Slack and
is located in the Company's file. During the visit, the biofilter was observed in operation with no odorous emissions.
The biofilter has been operating with no odorous emissions during all recent visits to the facility. Therefore, I have begun
instructing several of the complainants to contact Water Quality in reference to odors coming from the waste water
treatment facility.
Surveillance should be continued at this facility to insure compliance with the visible emissions and odor standard.
* Note: Odor evaluation intensity scale: 0 = no odor; 1 = very faint odor; 2 = faint odor; 3 = easily noticeable
odor; 4 = strong odor; 5 = very strong odor.
BWA:s1

Fir
County: 6
Responsible Partyt"
Address & Phone Number
Nature of Complaint: od oll i
Division of Air Quality Complaint Form
Date: )4,-' 1 Time: / Y
Repeat Caller?
Note:
cnt duration, any health effects, and any damage to property. Get as muck detail as possi
Directions to Site:
Note: Verify these directions by repeating there to the caller.
Is this complaint: Anonymous
Note: Confidential complainant in
only if time allows.
Follow-up requested: None
Note: Only two attempts will be made to contact the complainant by phone. If the co rrplaint is allowed Grp by phone,
a lerter will not be sent
Confidentia
ion tat% not be written on
Regular
Anonymous calls will be invstigated
Name of Complainant:
& Phone Number
Address:
Call Back
Call Received by:
Date(s) Investigated:Date Letternt; (or) Dates Cat4ed:
Conuaents:
by:
Data Tracking: 0 COMPLAIN 0 I -STEPS Action Number:

Division of Air
County: Date:
Responsible Party
Address & Phone Number
�t►aii1
Complaint Form
Tim
Nature of Complaint,:
• Document duration, any
Directions to Site:
effects, and any damage tea property. Get as much detai
directions by repeating them to the caller..
Is this complaint: Anonymous Confidential Regular
Note: Confidential complainant information may not be written on this form. Anonymous cal
only if time allows,
Follow-up requested:_ Call Back None
Note: Only two attempts will b made to contact the complainant lay phone. If the complaint is followed up by phone,
a letter will not be sent. -.
g
Name of Complainant:.
& Phone Number
Address:
ki4
Call Received by:
Date(s) Investigated: Date Letter Sent:
Comments:
Complaint Investigated by:
Dates Called:
Data Tracking: CO PLAIN I -STEPS Action Number: 1 1

County:
Division of Air Quality Complaint Form
Responsible Party
Address & Phone Number
Date:
Za
3— Time: °" 1 ',c) Repeat Caller?
Nature of Complaint:
Note. Document duration, any health effects, and any damage to property. Get as much detail as possible.
Directions to Site:
Note: Verify these directions by repeating them to the cal
Is this complaint: Anonymous Confidential
Note: Confidential complainant information mad# not be written on this form. Anonymous calls will be investigated
only if time allows.
Regular'
Follow-up requested: None Call Back Letter
Note: Only two attempts will be made to con!oct the complainant liy phone. If the complaint is f allowed up by phone,
a letter will not be sent.
Name of Complainant:
& Phone Number
Address:
t
Call Received by: —e)11
Date(s) Investigated;
Comments:
u..
Complain( Investigated by:
wnt (or) Dates Called:
Data Tracking: COMPLAIN
Action Number:

County: -, ,T
Responsible Party
Division f Air Quail ty Complaint Form
Date:
Address & Phone Number
Nature or Complaint;
Time: ° $
Repeat Caller?
Note: Document duration, any health e,ects, and any damage to
Directions to Site:
Note. l✓ertt these directions by repeating them to the caller.
Is this complaint: Anonymous Confidentia
Note: Confidential complainant in, or, at'on may not be writ
only if jtime allows.
Follow-up requested: None Call Back
Note: Only two attempts will be made to contact the complainant bl• phone. Ithe corn
a letter will nor be sent.
Name of Complainant:
& Phone Number
Address: 2.152-2—
Call Received by:
er
gated
owed up b►} pl
Date(s) Investigated:
Comments:
Si)
Comp
nt:
ed by:
(or) Dates Called:
Data Tracking: 'COMPLAIN *1.STEPS Action Number:
Personal Log

Division of Air Quality Complaint Form
County:
Responsible Party
Address & Phone Number
Nature of Complaint:
Note: Document duration, any health effects, and any damage to property. Get as much detail s possible.
Directions to Site:
Note: Verify these directions by repeating them to the caller.
Is this complaint: Anonymous Confider ti
Note: Confidential complainant i
only if time allows.
Lion may not be written on
Follow-up requested: None Call Back
Nose: Only two attempts will be made to contact the complainant by phone. 1 `the complaint is, ollowed up by phone,
a letter will not be sent.
Regular
nymous can's will be fnvesti,gat d
Name of Complainant:
& Phone Number
Address:
Call Recei ed by:
Date(s) in
Comrrae€tta:
Z.1r 5` --
/
Complain* ! yr tig;atetl by:
Date Letter Sent:
Data Tracking: CO EPS Action Number:
Letter
or) Dates Called:
oral Log

AQ-16 Revised 9/19/95 GADEM1AQ1WPDATANCOUNTIESGASTON1000261970122,
NORTH CAROLINA DIVISION OF ENVIRONMENTAL MANAGEMENT
Name
CBP Resources
Air Quality Action Report
Location
Gastonia, Gaston County
Reg/Co./Prem.No.
03/36/00026
Contact
Telephone
Type Action: CIS EE
Air Program Status: 03 93
Action Requested By:
Other: Surveillance
Class: _A_
Address/Phone
Change to:
Rec'd Date
Last Insp. Date 12/20/96
Action Date 01/2
Permit # 3590R13
Data Tracking: 0 EMS
Recommendations:
Continue Surveillance
Issued 9/19/96
0 TOXLB
97 Next Insp. Date Ongoing
Surveillance
Expires 6/30/97
0 COMPLAIN 0 1-STEPS Action Number: 128
Signature:
Ronald E. Slack
This facility is a rendering plant that mostly processes chicken blood and fbthe
food manufacturers. It is located approximately one mile north of the NC SC state line on Highway 321
(5533 South York Road) in southern Gaston County, North Carolina.
t_
Date:
Iyq/7
material for dog
This report was generated by 6 odor complaints received on Tuesday, January 21, 1997 and Wednesday,
January 22, 1997.
At approximately 10:00 A.M. on January 22, 1997, Barry Addertion and Ronald Slack conducted a
surveillance around CBP to determine what type of odor residents of Saddlewood Subdivision were
experiencing. Light odors, that apparently came from CBP, were identified in the Subdivision. The actual
CBP process that produced the odors could not be determined from the smell.
A check of the p1t4ennined that the wastewater lagoons were still producing odor, but the odor was
approximate1(50 percent 6f the intensity identified by Mr, Slack in December. Apparently the odors are
slowly improving.
The biological filter was operating properly. A lot of steam was seeping through the wood chips but only
a very mild odor similar to wet wood was present.
The circular chart that recorded temperatures in the feather processor during the past 24 hours was checked.
Two peaks, occurring the 30 minutes around 4:00 A.M. and the one hour around 5:00 A.M. on January 22,

1997, were identified as possible problem areas. Mr. Meriting, CBP Vice President, stated he would
interview e night operator to determine what caused the peaks. Production rates were also checked, The
lty processed approximately 13,000 pounds of feathers per hour during the past 24 hours, This process
e i less than the maxi process rate in the SOC agreement.
On January
feather proses
23 1997, Mr. Olberding reported that the plant operator had tried to
Shen the blood plant had some problems, and this caused tempe
Recommend biweekly suane through the 9[areh 1997.
�nblood
tt
es to peak.
ough the

Corporate Office
CBP Resources, Inc.
November 19, 1997
Mr. David Goodrich
Division of Water Quality
Permits and Engineering Unit
NCDEf1NR
P. O. Box 29535
Raleigh, NC 27626-0535
Re: CBP Resources, Inc., Gastonia, NC.
NPDES Permit NO. NC 0005011
Dear Mr. Goodrich:
During our meeting of November 8, 1.996, the issue of a Wastewater Disposal
Alternatives Report (Report) for CBP Resources, Inc.'s (CBP) Gastonia plant
discharge was discussed.
The alternative cost analysis for the Gastonia operation must take into account the current
and future requirements of the poultry industry in the State of North Carolina. This has
been a fairly complicated task and has required significant interaction between CBP and
its raw material suppliers.
In addition, CBP has been working with the City of Gastonia Department of Public
Works in determining the feasibility ofa sewer connection to the Crowders Creek.
municipal wastewater treatment plant (Plant) and the ability of the Plant to receive and
process industrial wastewater discharge from CBP's Gastonia operation.
Corporate:
Post Office Drawer 20687
Greensboro, NC 27420
940-333-3000
Fax # 940=378-0435
Divisions:
Carolina By -Products Co,
Greensboro, NC
Cape Fear Feed Products, Co,
Fayetteville, NC
Direct Dial Number;
Gastonia Division
Gastonia, NC
Knoxville Division
Strawberry Plains, TN
Norfolk Tallow ° Co,
Chesapeake„ 'VA
Chemol Co,
Greensboro, NC

Page
Finally, the alternative cost analysis requires active input militants n
equipment suppliers fora meaningful comparison of the alte abyss being considered..
I3P has been working actively with independent consultants representing the City o
Gastonia and Cf3P in developing the cast analysis which has required the cooperation
from equipment suppliers as well.
Barring unforeseen circumstances, CI3P will have the Repo delivered to the NCDEHNR
on or before January 1, 1997.,
In the mearuitne, if you have any questions, please let us l rio a.
Sincerely,
Mel Roshanravan
Vice President
Environment & Science
c : Gene Olberding
Van Jones
Dennis Ramsey - l 'CDE l
Rex Gleason - lot l

DIVISION OF WATER QUALITY
October 23, 1997
TO: Bob Sledge
FROM: D. Rex Gleason
PREPARED BY: Richard Bridgernan
SUBJECT: Composite Samples
Your package of requests to collect composite samples using a constant volume constant
time method has been reviewed. The following recommendations are offered:.
Hoechst Celanese/Salisbury Plant (NC0004944/Rowan Co) - Discharge is
manually controlled, which can insure that effluent flow rates vary by less than
15%. Influent monitoring not required. Approval is recommended.
CBP Resources (NCO0O5O11/Gaston Co) - The submitted flow chart does not
indicate period represented. Discharge is manually controlled, which can insure
that effluent flow rates vary by less than 15°/©. Influent monitoring not required.
Approval is recommended.
Minette Mills, Inc. (NC0004235/Cleveland Co) - Flow chart indicates that period
represented is during July Fourth Holiday week. A review of self -monitoring data
suggests that the chosen week is not representative. A discussion with WQ staff
familiar with the facility disclosed that a consistent flow from the aeration basin
may not be as easily controlled as the company's letter suggests. It is
recommended that approval not be given unless the company can provide
additional supporting information,.
Cedar Park Estates (NC0034711/Cabarrus Co) Flow chart does not specify
period represented; however, flow definitely varies by greater than 15%.
Approval is not recommended.
Chemical Specialties, Inc. (NC0006351/Cabarrus Co) - Contrary to letter, flow
chart indicates that flow does vary by greater than 15% over a 24-hour period.
Approval is not recommended, unless company can provide additional supporting
information.

Bob Sledge
Page Two
October 23, 1997
Lincoln County/Middle Forney Creek. (NC0074012/Lincoln Co) - Situation at
subject facility, as decribed in letter, is understood; however, discussion with WQ
staff having WWTP operation experience disclosed that a meter calibration
technician may be able to enhance the meter's `low end" capabilities. Approval is
not recommended, unless the County can document that the meter is operating at
the limits of its capabilities and that flows over 24-hour periods do not vary by
greater than 15%.
A determining factor in our recommendation is the fact that the facility's
computer -generated flow chart does not continuously record the flow in a manner
which demonstrates variations. The submitted 24-hour "chart" for the
approximate period from 11:00 AM on 9/30/97 to 11:00 AM on 10/1/97 consists
of only 11 data points. Although the Division apparently approved the
system, the permit condition to continuously monitor/record flow is clearly
not being met; therefore, it is recommended that WQ permit staff review the
equipment for adequacy (FYI - Mary Cabe and G.T. Chen processed last permit
related action).
Any facility which receives approval to collect composite samples using a constant
volume/constant time method should be made aware of the conditions which must be met to
comply with the definition of the method. Neither Hoechst Celanese nor CBP Resources seem to
be fully aware of the method definition. In granting approval to collect constant volume/constant
time composite samples, the Division should be careful to differentiate between influent and
effluent samples; an effluent controlled to a point to meet the conditions of the method definition
does not necessarily mean that a variance should also be given for the influent sample collection.
Contact the writer if you have questions.
File h:lwpwinldoc\memolsledge.fps

Gastonia Division
CBP Resources, it
RE LING. Bt.lsx
July 21, 1997
Mr. D. Rex Gleason, PE
Acting Regional Supervisor
Division of Water Quality
919 N Main Street
Mooresville, NC 28115
Subject: Notice of Recommendation for Enforcement
CBP Resources
Gaston County, NC
Dear Rex,
This is in response to your July 8, 1997 Notice of Recommendation for Enforcement,
While we do not dispute the facts that constitute the referenced violations, we believe that
our ongoing efforts ( the addition of four, 40 horsepower aerators at a cost of $78,000) to
achieve and maintain compliance and to eliminate the direct discharge to Crowders creek
weigh against any recommendation for enforcement.
We have been working diligently toward a tie-in to the City of Gastonia's municipal
system so that our direct discharge can be eliminated. Our company also is committed to
making the financial investment necessary to remove the discharge from the creek as soon
as possible.
We request that your recommendation for enforcement. be deferred at this time so that we
may concentrate our efforts on connecting to the City. Presently, our design engineer is
working on plans to make this tie-in. Thank -you for your consideration.
Should there be any questions, please contact Mr. Van Jones or me,
Sincerely,
ene Olberding
Vice -President of operations'
5533 S. York Pd_ • Gastonia NC 28052 • 704-864-9941 • Fax a0 861 922 • Direct Dial Number: w.

JUN 11 '97 et9*12Ah1
Huns, Jr., Governor
Department of Env
ems:
Date:
Immediate
6/10/97
GA
P .12
Jonathan H. Howes, Secretary
North Carolina
onrnent, Health and Natural Resou
irrltwwt: Eijnie Seneca 919 733 5083
fistributiotr: Targeted
es
x208
hearing set June 12 on CBP Resources request
ew and expand its wastewater treatment plant
The N.C. Division of Water Quality has scheduled a public
y (Jtme 12) can CBP Resources request to renew and expand its
t plant.
Details of the draft wastewater permit be presented and public comments
accepted at the hearing which begins at 7 p.m., Grier Junior High School, 1622 E.
Garrison Blvd.
Under the proposed wastewater permit scenario. the render ng company would be
required to counect to Gastonia's Crowders Creek wastewater treatment plant within two
years. The company would not be able to expand its discharge volume and it would have to
meet reduced pollutant loading.
"The City, of Gastonia has a rmt
advanced treatment plant and is designed to meet.
limits," said Steven Pellei, the division's environmental engineer overseeing the
renewal. "Improving water quality in Crowders Creek is our goal with CBP's de -on
to the city."
Since 1946, CBP has operated the rendering facility at 5533 S. York Road. As part
of seeking renewal of its National Pollutant Discharge Elimination System (NPDES)
permit, the company requested an increase in the permitted flow.
For information contact Ernie Seneca, public information officer, Division of Water
Quality, N.C. Department of Environment, Health and Natural Resources. (919) 733-
5083, extension 208.
Public A fps Office
ox 27687, Raleigh, N.C. 27611
019) 715-4112
Director, Of

JUN 11 '97 09: 12Pel
P . 2/2
Wit, Fe.
S.C. Residents Rally Against N.C. Chicken
Plant
June 11, 1997 - 08:02 EDT
Bowling Green, South Carolina -- Spoiled meat and rotten eggs are making some South Carolina
residents sick enough to raise a stink.
North Carolina regulators will hold a public hearing on C.B.P. Resources' wastewater perrnit for Crowder's
Creek on Thursday night. The York County neighbors near the plant intend to let their feelings be known to
state officials.
The plant cooks chicken guts, blood and feathers down to a fine powder and sells it to pet and livestock feed
companies The gooey fat, which puts the shine in lipstick, is then sold to cosmetics companies.
The odor has been the least of the problems.
According to North Carolina records, C.B.P. violated its permit 22 times between July 1995 and June 1996.
Those records say the plant discharged too much waste into Crowder's Creek, too much ammonia and too
much fecal coliform bacteria.
Resident Jane Stang says she can't raise the windows at her home because the smell is too strong,
Prc.M
jiy not be published. broadcast.
Tyree yreelp,•cv,,,e,,v,v,,nr,v,,,, +.4 Y.V.V.101` V*,..W11.4.404/
Hoine law 1 Triangle I North Cautlitia
er e • ewer. weververe.r., e Wee
Copyright 01997
d an Jane 11, 1997 ai 08:04 AM
npanv, Raleigh, NC. Comments or questious7 Give us feedback

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. Van M. Jones
Environmental Manager
CBP Resources, Inc.
5533 S. York Road
Gastonia, North Carolina 28052
Dear Mr, Jones:
KAY 28 t997
Subject: NPDES Permit Renewal Draft
Permit N LIM ber: NC0005011
CBP Resources, Inc.
Gaston County
Attached to this letter is CBP Resourcesdraft NPDES permit for the facility located in
Gastonia. Any comments regarding the draft permit should be submitted no later than June 25,
1997.
The Division of Water Quality will hold a public hearing regarding the subject permit at
7:00 p.m, on Thursday, June 12, 1997. At that CBP will be afforded the opportunity to make
comment on the draft permit. The hearing will be held at the following location:
Grier Junior High School
1622 East Garrison Blvd,
Gastonia, NC
You should be aware that limits for certain parameters have changed. These limits are
based on the production numbers that were reported in your renewal application.
in addition, CBP's renewal package included a request for an increase of the average
monthly flow Emit from 0.257 MGD to 0.35 MGD due to an increase in processing. The Division
can not grant CBP's request for this expansion in flow due to the availability of a more
environmentally sound alternative.
Finally., it is the intent of the Division to issue this permit for a period of two years. After
which the permit will not be renewed,
encourage you to review these documents very carefully to ensure thorough
understanding of the information, conditions and requirements contained therein. Once a permit is
issued, except for typographical or technicai errors, the permit may be appealed only through the
legal process.
P.O. Box 29535, Raleigh, North Carol na 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

If you have y dusta ses tar comment r c irz the draft
Steven P ll i at (919) 733 508 3, t nsion 516:
I0Iaby Blo8ve
Moo le Region
Permit File
Sincerely,
David A. Goodrich, uprvi
NPDES Group

Permit No, NC
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE EL MINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
CBP Resources, Inc.
is hereby authorized to discharge wasewater from a facility located at
Gastonia Division
US Highway 321
Gastonia
Gaston County
to receiving waters designated as Crowders Creek in the Catawba River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I,
and TV hereof,
The permit shall become effective 'WM, 1997
This permit and the authorization to discharge shall expire at midnight on September 30, 1999
Signed this day Y, 1997
DRAFT
A. Preston Howard, Jr., P,E,, Director
Division of Water Quality
By Authority of the Environmental Management Commission

is hereby authorized to:
SUPPLEMENT TO PERMIT COVER SHEET
CBP Ftescitirces, Inc,
Permit No. NC(1(105011
1. Continue to operate the existing 0,257 MGD wastewater treatment facility (outfall 001)
consisting of an activated sludge WWTP, polishing ponds, and chlorination facilities, and
2. Discharge non contact cooling water (butfall 1102) from facilities located at Gastonia Division,
US Highway 321, Gastonia, Gaston County (See Part III of this Permit), and
3„ Discharge from said treatment Works at the locations specified on the attached map into
Crowders Creek which is classified C waters in the Catawba River Basin,

Bowling Green;,,
ROAD CLASSIFICATION
PRIMARY HIGHWAY
HARD SURFACE
SECONDARY HIGHWAY
HARD SURFACE
IM'RO©EQ UTY UURRFFACEARDDR
UNIMPROVED ROAD
Latitude 35°6g'41" Longitude 81°11'21"
Map # G14NW Sub -basin 030836
Stream Class C
Discharge Class ooI:3:az�
Receiving Stream Crowders Creek I Catawba. River
Design Q 0.257 MGD Permit expires 9/30/01
SCALE 1:24 000
0
1 MILE
�wv
7000 FEET
1 KILOMETER
CONTOUR INTERVAL 10 FEET
CBP Resources, Inc.
NC6605611
Gaston County
WWTP
IMMO

A(1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0005011
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outtl serial number
001. Such discharges shall be limited and monitored by the Permittee as specified below:
ill
rage
xi
aftu
Measurement
Frequency
S rnple,
Typo
Flow
BOD, 5 day, 20 C
NH3 as N
Dissolved Oxygen
0.257 MGD
366
Ibs/day
126 Ibs/day
612 lbs/day 143 mg/I _ 285 m
252 lb day
Continuous
Weekly
Weekly
Weekly
order
Cornposiie
Composite
Grab
IorE
E,U,D
Total Suspended Residue 378 lbs/day
Fecal Colif rm ltleom tr"c rrra
0
Oil Grease
er
an
Total Nitrogen (NO2 NO3++ TKN)
Total Phosphorus
Temperature
pH2
Chronic Toxici
Notes:
2
180 lbs/day
756 Ibs+day
360 Ibs/day
400
1©Q mi
Weekly
Weekly
Weekly
ly
Weekly
Weekly
Quarterly
C©rnp©site
Grab
Grab E
Composite
Composite E
Grab E, U, D
Grab
Composite E
Sample locations: E - Effluent, I - Influent, U - Upstream at US Highway 321, D - Downstream at SC Highway 654, Upstream and downstream monitoring is to
be conducted weekly.
The pH shall not be less than 6.0 standard units nor greater than 9,0 standard units.
Chronic Toxicity (Ceriodaphnia) P/F at 3%; August, November, February, and May,. See special condition A.(3), on the Supplement to Effluent Limitations
and Monitoring Requirements Page.
There shall be no discharge of floating solids or visible foam in other than trace amounts,
Special permit conditions applicable to the subject facility are listed on the Supplement to Effluent
ations and Monitoring Requirements page.

A(2). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
Permit No. NC0005011
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outlall(s) numbered
serial number 002. Such discharges shall be limited and monitored by the Permittee as specified below:
Flow
Temperat
Total residual chlorine"
ure
Se
i-annually
Semi-annually
Semi-annually
Estirnate
Grab
Gra
Elflu
l
uent
Effluen
There shall be no chromium, zinc or copper added to the treatment system except as pre -approved additives to biocidal
compounds.
The temperature of the effluent will be regulated so that the temperature of the receiving stream does not increase more than 2.€3`C above the natural water
temperature and not exceed a maximum of 29°C,
Monitoring requirements apply only if chlorine is added to the treatment system,
The permittee shall obtain authorization from the Division prior to any use of biocide in the cooling water, The permittee shall notify the Director in writing at least
ninety (90) days prior to instituting use of any additional biocide in the treatment system which may be toxic to aquatic life (other than biocides previously
reported to the Division). Such notification shall include completion of Biocide Worksheet Form 101 and a map indicating the discharge point and receiving
stream.
The pH shall not be less than 6.0 standard units nor greater than 9.9 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts,

Part I Permit No. NC0005011
,Suoplerrtent to the Effluent Limitations and Monitorpnc
A (3). CHRONIC TOXICITY PASS/FAIL PERMIT' LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised November 1995, or subsequent
versions.
The effluent concentration at which there n tay be no observable inhibition of reproduction or significant
mortality is 3.0% (defined as treatment two in the procedure document). The peirnit holder shall perform
quarterly monitoring using this procedure to establish compliance with the permit condition. The tests will be
performed during the months of February, May, August, and Noveni.ber, Effluent sampling for this
testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGP3B.
Additionally, DWQ Form AT-1. (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of Water
4401. Reedy Creek Road
Raleigh, North Carolina 27607
y
Test data shall be complete and accurate and include all supporting chemical/physical measurements performed
in association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent
toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream,
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,
the peonittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating
the facility name, permit number, pipe number, county, and the month/year of the report with the notation of
"No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences
Branch at the address cited above.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will
begin immediately until such time that a single test is passed. Upon passing, this monthly test requirement
will revert to quarterly in the months specified above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this monthly test
requirement will revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to
include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls, shall
constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day
of the month following the month of the initial monitoring,
QCL PIF Version 9//96

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
JamesB. Hunt, J r., Governor
Jonathan B. Hewes, Secretary
A. Preston Howard, Jr,, P.E., Direct© r
June 26, 1997
Mr. Van Jones
CBP Resources
5533 South York Road
Gastonia, N.C. 28502
Subject. Chronic Toxicity Testing
CBP Resources
NPDES No, NC0005011.
Gaston County
Dear Mr. Jones,.
My staff has received. nd reviewed CBP Resources5/19/97 effluent toxicity report. During
review of the AT-1 form, our office noted the wrong effluent percentage was used. Therefore, we have
recorded the test as invalid,
As per CBP Resources' Irfnit requirement effective 1 l/1/95, a chronic pass/fail test is to be
performed quarterly at an effluent concentration of 3%. The AT-1 form indicates a chronic pass/fail test at a
eonccntration of 36% was performed. This letter is to inform you that you should decrease the tested
effluent percentage to 3% for future tests, as specified in the permit requirement.
If a "fail" was submitted on CBP Resources' monthly monitoring reports (DMR) for May 1997,
we remind you that the DMR. submitted to the Division's Central Files must be amended. The effluent
DMR facility information must be completely filled out (at the top of the sheet), and the form should have
"CORRECTED COPY" written or typed at the top. The parameter code of your particular toxicity test
should be re-entered in an appropriate column with a brief explanation that the test was not suitable as.
performed,
Please be aware of language present in your permit requirement that states, "Failure to achieve test
conditions as specified in the cited. document, such as minimum control organism survival and appropriate
environmental controls, shall constitute an invalid test and will require immediate retesting (within 30 days
of initial monitoring event). Failure to submit suitable test results will constitute noncompliance with.
monitoring requirements." Mr. John Baurnmer, with Burlington Research, informed our office that a.
toxicity test for CEP Resources has been scheduled for June, 1997.
If you have any questions regarding test protocols, you are epconraged to call me or Kristie Robeson at
[phone].
Rex Gleason-MRO
John Baummer-Burlington Research, Inc.
Shannon Langley -Facilities Assessment. Unit
Central Files
Environmental Sciences Branch
Telephone [phone]
An Equal Opportunity Afrurn,ativc Action Employer
y
Supervisor
Aq .' t e d Toxicology Unit
4401 Reedy Creek. Road Raleigh, North Carolina 27607
FAX # [phone]
50% recycled/10% post consumer paper

RECYCLING,
July 10, 1997
OF OUR BUSINESS.
Mr. John Leslie
NC Division of Water Quality
919 N Main Street
Mooresville, NC 28115
Subject: Power Outage
CBP Resources WWTP
Gaston County, NC
Dear Mr. Leslie:
Gastonia Division
CBP Resources, Inc.
This is to document our phone conversation on July 7, 1997.
At this time I advised that our electrical delivery, servicing our aeration equipment at the
wastewater treatment plant, had been interrupted in order to have a larger transformer
installed. The purpose of this was to allow the installation of more aeration equipment.
The contractor who was installing the underground wires cut the return sludge line. The
broken line was corrected promptly and placed back in service. The power was restored to
the aeration equipment at 1800 hours.
Should there be any questions, please let me know.
Sincerely,
ones
Environmental Manager
5533 S York Rd. • Gast.ronua, NC 28052 • 704-864 9941 • Fax # [phone] • Direct Dial Number:

1R:lIALiL.,. F EAtil..LY
\ ITC )1.4N Is1` l �I NF.fi.1l.
Mr. Richard Penegar
O.G. Penegar Company, Inc.
P,O, Box 839
Gastonia, N.C. 28053
State of North Carolina.
1 )t•I)ilr1l 1(rlt ( IiLSti('(_
I'' ().1%(IXLi' )
September 24, 1997
REPLY TO: J. Allen Jernigan
Environmental Division
Tel: [phone]
Fax: [phone]
RE: CBP Resources' Gaston County Chicken Processing Facility
Dear Mr. Penegar:
Your letter dated September 8, 1997, to Attorney General Michael F. Easley concerning
CBP Resources' Gaston County facility has been referred to me for response. The Attorney
General thanks you for your letter and appreciates your concern over continuing water quality
and odor problems arising from CBP's rendering operation.
Last year, the Division of Air Quality of the Department of Environment and Natural
Resources ("DENR") levied approximately $15,000.00 in civil penalties against CBP for
violations of state air quality laws. In response to the Division's penalty assessment, CBP
entered a Special Order By Consent, effective December 13, 1996. As an initial matter, the
Special Order required that CBP pay $28,000.00 in settlement of all noticed violations of state
visible emission and odor laws. The Special Order further required CBP to construct and install
a biofilter designed to reduce odors from the feather cooking process by 75 to 95%. Through the
Special Order and subsequent air permit modifications, the Division of Air Quality has also
imposed several operational requirements upon CBP to further control odors, including the
construction and operation of a separate blood processing plant and a 2,3000,000 pound weekly
limit on the amount of feathers and blood processed.
We have been working with DNER to determine whether technical data demonstrates
violations of State water or air quality standards at the facility sufficient to warrant additional
legal action. Presently, DENR has not referred this facility to our office for initiation of a civil
action for injunctive relief to restrain the operation. 1 have been advised that DENR is reviewing
this situation and others where odor and water quality concerns appear directly interrelated.

September 24, 1997
Page
Your attached letter of SepteSeptember 8, 1997 to Mr. Kirsch also inquired about the status of
CBI's pending water quality permit modification application. It is my understanding that the
application is still pending. By copy of this letter, I am referring your concerns and questions to
Preston Howard, Director, N.C. Division of Water Quality and Mr. Alan Klimek, Director,
N.C. Division of Air Quality for further investigation and a more detailed response, as they are
the responsible permitting agencies.
If you have further questions about this faci
y, pleas
cc Preston Howard, Director, Division of WaterQual
Alan Klimek, Director, Division of Air Qual t
EP\d 783-1
feel Free to contact me.
Very t ly yours,
J, Je
Special Dep
ey General

Interior Design Space Planning Office Furniture Systems
O. G. Penegar Company, Inc.
P.©. Box 839 • Gastonia, NC 28053
704/865.1236 375-5586
September 8, 1997
RECEIVED
SEP 1 2 199/
N.C. ATTORNEY GENERA.
Environmental Oivisiofl
Mr. Mike Easley, Attorney General
PO Box 629
Raleigh, NC 27602
Dear Mr. Easley,
OF ATTORNEY GENERAL
RECEPIETJ
SEP 1© 1997
Congratulations are due to you and your and staff for taking
the time and making the effort to do something for all. North
Carolinians - closing the Purvis hog operation in Montgomery
County. There is no need to tell you all the good reasons,
certainly this action sends a statement that your office is not
going to tolerate such abuses to our rivers and streams.
The reason for getting in touch with you at this time is to
ask you to do the same thing for this part of the, state. Our
problem is not swine lagoons but chicken entrail lagoons polluting
water and air quality in Gaston County.
Enclosed is the letter I have sent today to Herbert Kirsh who
has come to our assistance from the South Carolina side. The
people in his county and much of the piedmont of South Carolina are
also effected by this constant pollution.
I hope you can ask someone in your department to give some
attention to this matter. Enough is enough, 20 years and it still
goes on. If there is any way we may assist you please feel free to
call.
Sincerely,

Interior Design Space Panning Office Furniture Systems
0, G. Penegar Company, Inc,
P0 Box 839 • Gastonia, NC 28053
704/865-1236 375-5586
September 8, 1997
Mr. Herbert Kirsh
House of Representatives of SC
Box 31
Clover, SC 29710
Dear Mr. Kirsh,
Thank you for copying me and others with your letters to DEHNR
in your efforts to clean up the air and water pollution at the CBP
location near our homes. I wish you well in your endeavor.
In one of your letters you mention that this problem has been
going on for 10 years. As a matter of fact we have been patiently
trying to correct the problem with CEP and its predecessor
corporations by talking with them and talking with the Regional as
well as the NC State Department of Environment Health and Natural
Resources for over 20 years - - to no avail.
There is technology Mr. Kirsh, to correct this problem. A
good corporate citizens and a truly concerned State Agency would
spend the money to do it. Mr. Landis is less than truthful when he
tells you in his letter to you of August 29th when he says these
odors are characteristic of this type of treatment system. He
fails to tell you that other States use different ways of doing it
and thus eliminate the odor. He also fails to tell you about the
uncovered, untaxed trucks parked in the hot sun for hours waiting
to be unloaded. He also fails to tell you that because of the
expense of running the scrubbers they frequently cut them off
especially on the weekend when they know it will be difficult to be
reported. The law requires these people to run the scrubbers all
the time, but; "the State doesn't have enough people" to inspect
them everytime they turn off the air scrubbers, is frequently
DEHNR's excuse.
Recently (June 12) there was a hearing in Gastonia on CBP's
request for a peLuhit to increase their pollution into the creek,
ninety-nine percent of the opinion expressed at this hearing was
adamantly negative to renewing of the permit let alone increasing
it. Enclosed is a copy of my remarks at the hearing. You can see
the frustration of broken promises not only from CBP but from the
DEHNR. We have had no word from DEHNR in the 3 months since the
hearing!

Intenor Design Space Planning Office Furniture Systems
O. G. Penegar Company, Inc.
P,O. Box 839 Gastonia NC 28053
704/865-1226 375-5586
By copy of this letter I am informing the State of NC of our
continuing concerns and also the Attorney General asking him to
close this plant down as he was able to do with the hog operation
in Montgomery County - until it can meet State standards. There is
no excuse for this operation to continue to promise and never
fulfill its obligation to the citizens of our state and yours!
Let me thank you again and also offer to you the services of
the residents of the Crowders Creek area in any way that can help
our common cause.
CC: VMike Easley, Attorney General
David Hoyle, Member NC Senate
Jim Forrester, Member NC Senate
John Gamble, NC House Representatives
Dub Dickson, NC House Representatives
David Cline, Chairman Gaston County Commissioners
Steven Bryant, Aide to Governor Hunt

Wastewater in Cro
ders Creek
Stop the dumping, plant officials told
By Melissa Manware
The Herald
GASTONIA N.C. — One of the few things
people artending a water quality hearing
Thursday agreed on is that a North Carolina
chicken processing plant needs to stop
dumping its wastewater into Crowders
Creek.
The hearing, held by the N.C. Department
of Environment, Health and Natural
,Resources division of water quality, was to
*,eublic comment on CBP Resources'
•st to renew its permit to drain waste
water into the creek. CBP also wanted to
increase the amount of water it dumps.
The hearing was at a junior high school
in Gastonia.
York County residents who live in the
Bowling Green community have complained
for years that the rendering plant produces
a nauseating stench and is polluting the
water which eventually runs into Lake Wylie.
"I can't get away from the stink," said
Jeanne Foguth, who lives near the plant,
The stink comes from the 'water.. We can't
please see HEARING, back page
aring
from IA
eat on our back deck. We can bare-
ly eat inside,"
TheDivision of Water Quality has
tentatively recommended approving
the permit, but not allowing CBP to
dump more wastewater and requir-
ing it to hook on to Gastonia's waste-
water treatment plant within two
years.
Don Carmichael, Gastonia's direc-
tor of public works and utilities, said
CBP Resources has signed a letter
of intent to connect with the city sys-
tem. Five CBP representatives were
at the hearing, but none of them
spoke.
Tom Burton, a York County.
Councilman, said the agreement was
a step in the right direction, hut the
council thinks CBP ,shoulcin't be
allowed two years to make the .trae-
sition.
Marcus Norton, tile York County
planner, said one year should suf.-
ncc,
Others said the issue shouldnt be
- how long the rendering plant has to
comply. They want it shut down.
Understand that the conduct
of the applicant over its entire his -
tor/ at this plant has been a constant
stor: of delays and postponements,
of promises made and promises bro-
ken," said Richard Pe.negar, who .1
lives along Crowders Creek.
CBP violated its permit 22 times
between July 1995 and June 1996,
according to state records.
Bobby Blowe, who conducted the
hearing, said sending the wastewater
to the city plant would eliminate any
odors coming from the water. He
said, however, he didn't know how
much of the odor came from the
water.
Blowe asked the audience to save
their comments about the smeli for
an air quality meeting., Which he
promised would be held later this
year. Several people who had signed
up to speak passed when their turn
came, hut said they will be back to
address the pungent odor.
After the lel Rio sl anravan.
vice pres'..dent of the environment
for CBP Resources, admitted there
are"cdors associated" the chick-
en rendering process.
--What~.ve do is a tremendous son.
irake valuable products
from .vhat would otherwise go to
iantifills.” he said, adding that in
order to de7.n the air properiv,the
company needs to produce inure
h
b
Gastcnia sewage plant '
49
CBP Resour
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e
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Easley wants Mon oo
BY JAMES EL,1 SHIFTER
Attorney General Mike Easley
asked a judge Thursday to shut dawn
a Montg„ompry Co 41 hog farm
benuse a :‘lay 27 waste spill killed
hundreds of tish in a nearby creek.
The Riverside Farm, operated by
Purvis Farms Inc. of Carthage,
has a three-year history of tangles
with state environmental regula-
tors over its handling of swine
sewage. A waste spill in 1994 first
drew the state's attention to the
farm, and inspectors discovered the
next year that sludge from the
farm's waste lagoons was running
off a hillside into a stream, said
Tommy Stevens, the state Division
of Water Quality's regional super-
visor in Fayetteville,
e
hog farm close
In 'February, Purvis Farms paid a
S5,000 line and promised in a court
settlement to abide by a state -
approved waste -disposal plan,
Stevens said.
But an May 27, 3.000 to 4.000 gal-
lons of hog waste gushed out of a
hole in a pipe at Riverside Farrn,
Stevens said officials found 300 to
1.000 fish noating in nearby Dison's
Creek.
Only after inspectors arrived did
the farm's operators try to punrn
some of the waste out of the creek,
Stevens said.
"The rupture of the pipe is bad
enough, but the failure to act irnme-
diately to correct the problem and
prevent environmental damage is
intolerable," Easley said in a state-
mient. "State agencies have tried to
work with Purvis in the past.. hut
they simply refuse to act responsi-
bly These people need to he shut
down for good."
V.G. Purvis Farms operates nine
hog farms in Chatham, Richmond,
Montgomery, and .Moore counties,
said its treasurer, Jerry Purvis, The
company's recent efforts to expand
in Chatham and Moore counties
have brought opposition.
In response to Easley's effort to
get his farm declared a public nui-
sance, Purvis replied: "Mike Easley
is a public nuisance,"
A court hearing on the closure
motion is scheduled for June 1310
Randolph County
Thrnes Eli Shiffer can be reoched
at 836-5701 or [e-mail]

June 12, 1997
To Secretary Jonathan Howes and his appointed representation
holding this meeting.
Comments and Testimony an CBP Resources Application to Renew Permit
for RENDERING in Gaston County, NC and to Increase their daily
discharge from 270,000 gallons per day to 350,000 gallons per day.
I. My name is Richard Penegar, a resident and business owner
in Gaston County for over 50 years and a resident of
Crowders Creek - 1 mile west of the CBP plant for 21 years.
Thanks for allowing me the opportunity to make these
comments to the Department. Mr. Chairman here are my 3
copies of the prepared remarks as well as a copy of the
Gaston County Commissions Unanimous Resolution opposing this
permit, and the Commissions strong support of
public in part from individual citizens and the various
groups like the Lake Wylie Marine Commission, the CCEC,
and other water and air quality community action groups
from Gaston, York and Mecklenberg Counties who are also
victims of the Applicant's gross disregard for the
responsibilities and obligations incumbant under this
permit.
Also enclosed are several tax filing documents of the
Applicant which I hope you view as appropriate reflection
of the Applicant responsibility. It will show an additional
expenditure of over $500,000 in 1996 of expansion recycling
type of equipment (with no apparent improvement in the
pollution they are causing) and a total of $3,000,000 on
which they did not pay one cent of taxes to Gaston County.
This does not include any of the multi -million dollar fleet
of vehicles, tractors, trailers and the like on which they
also do not pay any property tax as they roll across the
roads of North and South Carolina.
My purpose here tonight is to offer some insight from the
public's point of view that will allow you people, the
Stewards, the Guardians of our Enviroment in NC - to take
action that will benefit the victims of your past action
and mistakes in dealing with this Company and their
practices at this plant in Gaston County.
You have already heard and will hear more tonight regarding
the horror of the fish kills and nauseating odors that
continually permeate the air for miles around the plant.

Since the early 90's these odors are the worst they have
been since 1976.
The pollution of our streams and rivers is bad enough all
aver NC but I suggest to you that this stream Crowder
Creek and this river, the Catawba, is just as important and
just as endangered as the Neuse and serves a vital, albiet
politically under represented, part of the state. Do we
need a Dr. Burkholder to get your attention?
I think not, what we first need to do is to get you to see
and understand that the conduct of the Applicant over its
entire history at this plant has been a constant story of
delays and postponements of promises made and promises
broken. Like the Tobacco Industries blantant denial of the
addiction of Nicotine, CEP insists through its actions that
a little amonia in the drinking water never hurt anybody
and that they don't smell anything obnoxious in the odors
thet produce.
What needs to be done, gentlemen, is first thing. Deny the
request for the increase in the discharge. Period.
Next, if you're not totally convinced that the permit
should be revoked permently you should give them no more
than a temporary permit - 90 days at the most to work out
a satisfactory agreement - satisfactory to you, Gaston
County and a local Citizens Committee, with the City of
Gastonia to handle all of the Waste Discharge from plant.
As a condition to the temporary permit CBP should be
required to post a minimum bond of $1,000,000 forfitted to
the State for failure to complete the work required within
one year from the date of agreement and a fine in the same
amount if the work is not completed within 6 months from
the date and full withdrawal of all permits to them or
succesors corporations for operating at this location
forever. Let them go to another creek nearer the center of
their customer base and start messing up someone else's
neighborhood.
The Applicant has lied to you and the people of NC too long
You have been misled - perhaps you have been too lax in
inforcing the Regulations of the State.
If someone lies to you once or twice it's nobody's fault -
but if you believe their broken promises over and over for
20 years you are as much the guilty party as they are. Your
commission is culpable in the victimization of the
citizens of this State as well as our neighbors in SC. And
you are responsible for bringing about a solution that stops
this pollution.
Sincerely,

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH AND. NATURAL RESOURCES
Division of Water Quality
919 forth Main Street Mooresville, North Carolina 28115
July 28, 1997
VAN M. JONES
CBP RESOURCES - GASTONIA DIV.
5533 SOUTH YORK ROAD
GASTONIA NC 28052
SUBJECT:
Notice of Violation - Effluent Limitations
NPDES No. NC0005011
CBP RESOURCES - GASTONIA DIV.
GASTON County
Dear VAN M. JONES:
Review of subject self -
of May, 1997 revealed violat
parameter(s):
Pipe Parameter
nitoring report for the month
n(s) of the following
Reported
Value/Unit
001 00310 BOD 389.00 LBS/DA
Limits
Value/Type/Unit
340.00 FIN LBS/DA
Remedial actions,, if not already implemented, should be
taken. to correct the problem( s) . The Division of Water
Quality may pursue enforcement actions for:• this and any
additional violations of State Law. If you have questions or i
you need assistance, please call D. Rex Gleason, Regional Water
Quality Supervisor, at 704/663-1699.
Sincerely,
D. Rex. Gleason, Acting
Regional Supervisor
cr tral. Files

State of North Carolina
Department of Environment and. Natural Resources
Division of Water Quality
919 North Main Street Mooresville, North Carolina 28115
October 24, 1997
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Van M. Jones
CBP Resources - Gastonia Div.
5533 South York Road
Gastonia, North Carolina 28052
SUBJECT: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No, NC000S011
CBP Resources WWTP
Gaston County
Dear Mr. Jones:
This is to inform you that a review of your toxicity self -monitoring report form
for the month of August 1997 indicates a violation of the toxicity limitation specified in.
your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the
conditions causing the effluent toxicity violations. Please be aware that North Carolina
General Statutes provide for assessment of civil penalties for violations of NPDES permit.
limitations and requirements. If it would be helpful to discuss this situation or possible
solutions, please contact Mr. John Lesley with this office at [phone].
Sincerely,
Barbara S. Christian, P.G.
Acting Regional Supervisor
cc: Central Files
Aquatic Toxicology Unit

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Water Quality
9 North Main Street Mooresville, North Carolina 281
September 10, 1987
VAN M. JONES
CEP RESOURCES GASTONIA DI V.
5533 SOUTH YORK ROAD
GASTONIA NC 2E052
SUBJECT: Notice of Violation - Effluent
NPDES Na ; NC000. Q 11
BB RESOURCES - GASTONIA DIV.
GASTON County
Dear VAN M. JONES:
ns
Review f subject self -mniorin report, for the ;month
f' July, 1987 revealed violation(a) of the fol iowng
parameter( ):
Ripe Parameter
001 00310 ROD
L units
Value/TypeUnt
518.00 LBS/DA 340.00 FIN LBS/DA
Reported.,
Value/Unit
Remedial actions, if not already implemented, should be
taken to correct the problem( ) , The Div.isien of Water
Quality may pursue enforcement actions for this and any
additional violations of State Law. If you have questions c
you need assistance, plsese call D. Rex Gleason, Regional Water°.
Quality Supervisor, at 704/663-1699
Centre Files
G .EDE. B/EL
Sincerely,,
B. Christian, Acting
Regional Supervisor

DEM-P & E
B_ Hunf, Jr.
Fax
Sep 8 '97 17:15
North Carolina
nt of Environment, Health and Natural Resources
contact
P. 01/01
Wayne McDevitt, Secretary
1;rnje S
(919) 733.083,
extension 2
esourccs denied permission to expand its wastewater
treatment plant, given 18 months to tie -into Gastonia's system
GASTONIA -- The NC. Division of Water Quality last Friday denied CBP
Resources request to renew and expand its wastewater treatment pIant, and has gives tt
rendering company 18 months to cease its discharge into Crowders Creek,
Preston Howard, division director, said CDP Resources will have to tie -into the
City of Gastonia's treatment plant. CBP renders inedible animal byproducts and waste
restaurant oils.
"Gastonia has a more advanced treatment plant desigd to meet stricter limits,"
said Howard, who denied the company's pemnit expansion request. The city has agreed to
the tie -on.
"We want to enhance water quality inn the Crowder Creek watershed and this is an
important stop in that direction," he added. "Nutrients flowing from the tributary into Lake
Wylie have been a concerti for us for some time.
Since 1946, CBP has operated the rendering facility at 5533 S. York Road. As part
of seeking renewal of its National Pollutant Discharge Elimination System (NPDES)
permit, the company had requested an increase iht the permitted flow from 257,000 to
350,000 gallons per day.
The Division of Water Quality held a public hearing .furze 12 in Gastonia,
announcing that the agency planned to deity the expansion request and require a city tie-in.
For information contact Steven Pellei, environmental engineer, Division of Water
Quality, N.C. Departnaent of Environment, Heald and Natural Resources, (910) 733-
5083, extension 516; or Ernie Seneca, division sporkesnraa, [phone], ext. 208.
Post -It' Fax Note 7671
To INA
r"'"' S. k.'L t. C
Phone •
Phone
Fax M

State of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr. o Governor
Jonathan B, Howes, Secretary
DIVISION OF WATER QUALITY
July 8, 1997
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. E.R. Olberding, Vice President
Carolina By -Products Resources
5533 South York Road
Gastonia, North Carolina 28052
Subject:
Dear Mr. Olberding:
Notice of Recommendation
for Enforcement
Notice of Violation NCGS 143-215,1(a)(6)
Compliance Sampling Inspection
CBP WWTP
NPDES Permit No. NC0005O11
Gaston County, NC
Enclosed is a copy of the Compliance Sampling Inspection Report for the inspection
conducted at the subject facility on June 26, 1997 by Mr. John. Lesley of this Office. Sample analysis
results will be forwarded under separate cover when available. The report should be self-
explanatory
This letter serves notice that the Mooresville Regional Office of the Division of Water
Quality is considering sending a recommendation for enforcement action to the Director of the
Division of Water Quality. The recommendation concerns the violation by this facility of North
Carolina General Statute 1.43-21.5.1 (a) (6) and NPDES Permit No. NC0005011 for discharging
waste into the waters of the State in violation of monthly average and daily maximum permit limits
for Ammonia as Nitrogen, daily maximum effluent limits for Fecal Coliform, monthly average
limitations for Flow and BOD, and Chronic Toxicity limit violations (See the Self -Monitoring
Section of the subject report).
919 North Main Street,
Mooresville, North Carolina 28115
Voice '704-663-1699
FAX 7D4-663-6040
An Equal Opportunity,/Affirmative Action Employer
50% recycled/ 10% post -consumer paper

CBP Res urc
Page 2
f you have xpl ation for the violations that you wish to present, please respond i
writing within ten (10) days folio ing receipt of this Notice. Your explanation will be reviewed and
an enforcement action is still deemed appropriate, your explanation will be forwarded to the
Director with the enforcement package for his consideration. Please address your response to my
attention at the address shown on the letterhead,
fyou ha
663-1699.
e as y questions concerning this Notio , please contact
Sincerely,
D. Rex Gleason., P.E.
Acting Regional Supervisor
oinpli
Central Files
oresiile Regional Office
Gaston County .l- ealth Department
rent
ent Group
esle
or e at 0

Or*
United States Environmental Protection Agency, Washington, D.C., 20460
NPDES Compliance Inspection Report
Form Approved
OMB NV2040-0003
Approval Expires 7-31-85
Section A: National Data System Coding
Transaction Code NPDES YR/MO/DAY Inspection Type Inspector Facility
Type
N NC00050 97106/26 a a 2
Reserved
Facility Evaluation Rating
2.
Section
Name and Location ofFacility nspected
CBPResources WWTP
Highway 321 South
south of Gastonia, Gaston County, North Carolina
BI
: Facility
Name(s) of On -Site Representative(s) Title(s) ------ Phone No(s)
Mr. Van Jones / Environmental Manager / [phone]
Name, Address of Responsible Official
Mr, E.R. Olberding
CBP Resources
5533 South York Road
Gastonia, North Carolina 28052
QA
Entry Time:
2:00 pm
Exit Time/Date:
3:00 pm
97106/26
Title
Vice President ofOperations
Phone No.
[phone]
Pemiit Effective
Date:
November 1, 1995
Permit Expiration
Date:
September 30, 1996
Contacted?
NO
Section C: Areas Ealuated During Inspection (S-Satisfactory, NI -Marginal, U-Unsati o N-,Not Ealuated, NA -Not Applicable)
n nn
M Permit
a Records/Reports
5 Facility Site Review
S Flow Measurement
Laboratory'
Effluent/Receiving Waters
Section B:
NA Pretreatment: S Operations & Maintenance
NA Compliance Schedules N. Sludge Disposal
S Self -Monitoring Program * Other: Sample analyses
of Findings/Comments
See Attached Sheet(s) for Summary. * Sample analysis results will be forwarded under separate cover
when available.
Name(s) and Signature(s) of Inspectors Agency/Office/Telephone
John Lesley 1-/1
Signature of Reviewer
Action Taken
NCDWQ/MR0/[phone]
Agency/Office
Regulato
Use Only
Date
Date
July 8, 1997
Date
Date
Noncompliance
Compliance
EPA Form 3560-3 (Rev. 3-85) Previous, editions are obsolete

Facility Name:
CBP Resources WWTP
NPDES Permit Number:
NC0005611
The facility was last inspected by Patricia Beam of this Office on December 3, 1996. Joint
inspections were conducted by DWQ staff and Division of Air Quality staffon February 2.5 and 27
and March 3 and 20, 1997. The joint inspections were in response to numerous odor complaints
reported to this Office during the period from January through March, 1997.
PERMIT:
The permitted facility (outfall 001) is a 0.257 MGD activated sludge wastewater treatment
plant consisting of an aerated lagoon, secondary clarifier, effluent polishing ponds, a stormwater
lagoon, a chlorine contact chamber with gas chlorine disinfection, a sludge filter press, and
continuous flow measurement. The facility's NPDES Permit expired on September 30, .1996. An
application for renewal of the permit with all applicable fees was received by the Division on March
29, 1996. The facility continues to operate under the conditions of the expired permit.
Outfall 002 is a non -contact cooling water discharge. Cooling water is pumped from.
Crowders Creek to the manufacturing plant's cooling system and discharged as described in the
Permit. The non -contact cooling water contains no biocides or chemical additives.
On January 14, 1997 CBP Resources submitted an Alternatives Analysis Report comparing
costs associated with meeting monthly nutrient limits of 1 mg/1 Total. Phosphorus and 6 mg/1 Total
Nitrogen to the cost of connection to the City of Gastonia collection system. Based upon the
Alternatives Analysis, CBP Resources has proposed a 5-year phased tie-in to the City of Gastonia
Crowders Creek WWTP contingent upon a pretreatment agreement with the City.
The existing permit limitations are based on the production based limits found in 40 CFR 432
Subpart J - Render Subcategory, The limitations found in 40 CFR 432.102(a) do notadequately
protect the receiving stream for fecal coliiform. A water quality standard of 200/100 ml has been
established to protect human health [15A NCAC 2B.0211(e)] ; whereas, 40 CFR 432.102(a)
requires a 400/100 ml daily maximum limit for fecal coliform. It is recommended that the Division's
Permits and Engineering Group base the facility's fecal coliform limitations upon the water quality
standard to ensure adequate protection of human health at permit renewal.
FACILITY SITE REVIEW/OPERATION AND MAINTENANCE:
The facility is adding four, 40 horsepower aerators to the aerobic lagoon. Electrical service
was upgraded by Duke Power Company on July 7, 1997 according to telephone notification from
the ORC on. July 7, 1997.
The mixed liquor in the aeration lagoon appeared to be a dark brown color with no excessive
foaming. Dissolved oxygen concentrations in the basin are usually between 1.0 mg/1 and 0.5 nig/1
according to process control records. Odors were consistent with the findings of the joint inspections
conducted in February and. March, 1997 (see above) and were most noticeable at the influent end of
the aeration lagoon.
The effluent polishing ponds appeared to be a "red -purple" color. Red algae was the cause
of the discoloration according to the ORC. The effluent polishing ponds are operated in series.
Denitrification was observed in the first polishing pond.

CEP Resources NC0005011
Chlorine gas disinfection is accomplished by utilizing a one -ton chlorine cylinder located
approximately 100 yards from the chlorine contact chamber. The chlorine cylinder is on the ground
exposed to the elements. It is recommended that chlorine cylinders be stored in a building or other
secured area equipped with the proper safety devices (exhaust fan, chlorine gas leak detector, alarm
system, etc.).
A process control program consisting of dissolved oxygen, pH, settleable solids, and
temperature measurements and MLSS, MLVSS, TSS, and COD testing is used in the operation of
the facility.
SELF -MONITORING PROGRAM:
Monthly monitoring reports were reviewed for the period from July, 1996 through April,
1.997. Twenty-four (24) daily maximum permit limit violations were reported for fecal coliform
during the period. Four daily maximum peimit limit violations and one monthly average permit
limit violation for ammonia as nitrogen were reported in July, 1996. Toxicity failures were reported
in September and November, 1996. Monthly average limit violations for flow and BCD were
reported in February, 1.997.
Time -based composite samples are collected. Part 11, Section B, Paragraph 8 of the NPDES
Permit requires that samples be collected proportional to flow. Should the facility seek Division
approval to continue utilizing time -based composite samples for monitoring purposes, a written
request must be m.a.de to the Director. Supporting documentation which includes a description of
the flow measuring device, a representative sample of one week's flow data (chart recordings), a
description of the sampling method (constant tim.elconstant 'volume, variable time/constant volume,
constant time/variable volume„ etc.), and a description of any flow equalization used at the treatment
facility must accompany the request.
Samples are collected on ice and stored at <4°C.
RECORDS AND REPORTS:
Records and reports consist of flow meter strip charts, ORE visitation calendar, operations
and maintenance log, laboratory reports, and monthly monitoring reports. All records and reports
are maintained in accordance with NPDES Permit requirements.
EFFLUENT/RECEIVING WATERS:
Samples were collected at the upstream, effluent discharge, and downstream locations.
Sample analysis results will be forwarded under separate cover when available.
The discharge was "red -purple" in color and very turbid. The upstream and downstream
were "red -purple" in color due to color impact from the City of Gastonia Crowders Creek WWTP
which discharges upstream of the facility. No adverse impact on the receiving stream was observed.
Continued noncompliance with permitted fecal coliform limitations (400/100m1; see Permit
and Self -monitoring Sections of this report) would predict an exceedance of the water quality
standard for fecal coliform (2001100m1) downstream of the discharge; therefore, the effluent
discharge is rated as "unsatisfactory".

F ENVIRONMENTAL MANAGEMENT WATER QC A FIELD -LAB FORM (DM1)
SPORT TO: ARO
AT BM
Other
Shipped by: 11
COLLECT011(S):
0 5WaR0 WIRO W'SR,O TS
PRIORITY
El AMBIENT 0 QA
DCOMPLIANCE El CHAIN
D
OF CUSTODY
EMERGENCY
Estimated BOD Range: 0-5/5-2.5/25-65/40-130 o 100 plus,/ STATION LOCATION:
Seed: Yes © No0 Chlorinated: Yes No 0 REMARKS:
9
10
11
12
�13
14
6
17
18
19
20
1)
3'10
/.1 High 340
Date Begin lyy/mrn/dd)
`I 7
Conform: MF Fecal 31616 /100m.
Collform: Tube Fecal 31615 /100m
Colllvrtna Petal Strap 31673 /100m'
due: Total 500
Vo#atfle 505
xed 510 mg/I
Residue: Suspended 530
Volatile 535
Fixed 540
Acidity to pH 4.5 436
Acidity to pli 8.3 435
Allkallnity to pH 8.3 415
TOC 680
Turbidity 76
piing Point %
units
Conductance et 25 C Water Temperetu
94
Salinity %
1de 745
ug/1
Pt -Co
ADMI
ADMI
mg/1
mg/1
' mg/1
mg/I
mg/I
Time 0egl
2 DO
Clifotlde 940
i
SAMPLE TYPE
© STREAM
Q LAKE
El ESTUARY
(CI )7e 21,l j t(s
fate End
EFFLUENT
INFLUENT
Time End
2l /ZDo
Chi e: Trl 32217 u
ChI a: Corr 32209
Pheophytin a 32213
: 'True 8
trlor: Pld 7.6 82
yanlde 720 __
aldehyde 71880
Grease and Oils 556
Hardness Total 900
Speclllc Cond. 95
RAS 38260T -_
27
Sulfate 945
O. mg/I
pill DM b0 DHM
or Lab Us
Y
DATA ENTRY
DATE REPORTED:_
Value Tyiir
A
I1113eeN610
NC12 talrrs NO3 as N 630
P 665 mg
PO4 aP 70507
P: llisst lved es P 666
Cu Coplxer 1042
NIkei 1067
Pb -Lead 105'1
2n-7lnc 1092
Ag-Silver 1077
Al-A1105
1#e»Beryliitarrt 1012
Ca -Celt lurn '916
o Cobalt 1037 mm
Fe -iron 11145
431
Turbidity Severl
p11 4,5
82243
y 4Wlnd Velocity
T) S 11
hlum 11.
Ium 927 mg
Ne-Sodium 929 m
Arsenic:Tn#at 1002 ugll
Se -Selenium 1147 ug/I
i#g Mercury 71,900 ug/I
Organochlorine Pesticides
Organoplro pborPectkhies
Acid lieriuc
ctnlrle Organics
Purgeable Ory anics (VOA bottle req'di
Phytnptanktan
Acidity Al
pil 8.3

couNty t GASTON
WALK liASIN
REPORT TO t
Other
CO171 E(TOR1S) :
Estimated HOD Range:
Ste&
NIRO [lenient)! Ofitice
LESLEY
Chlorinate&
DIVISION OF NVVIER. QUALITY
chenthfrytAlbormml RePort QHAlitY
,R,0R,,,,
0 AMURENT L1 QA
"CiLMPLIA NEE L. LIMN OE CUSTODY
EMERGENCY
S17)14111 tOCACiCIA; 4: Br I) ES(11) 17171 S
Remarks:
SAMPLE I'M
ri
snzrimi
LI L'A"
Ej ESTUARY
:Station
t005.11
27
I helt
1)70 Ruin ())/nmidd 17
970625
LES
'clicot re. 1591I real 310 i
entet'L
11001
r 1001
CatifortiL AIL Total 3.1504 tOrt
Ccenthrrn tube Fecal ) lit 5 t I 00tn
Cotiforrn 7e,.I Sirep 31673
fic5iduc Total 500
intarde 505
irised 0
I (ea oi
Resi t1C: Suspende
Anitttile 535
Fixed 5E)
pH 40 7
Addis!, In pH L 5 4.16
Acidity to I-
4 Al17 I7ni77' to p
A kalif -city to p
Turbidny '76
2,5e, Os 240
one)
top I,
70
units
COM)1EN 4AVIRIENT SAMPLE
711717„
ale CIO I :I. 1 rt1771 /71i17
Chloride 04
Uhl a 1 3217
Clil a Corr 32206
licophytin a:12213
Am Lute
:7..t11or (1774 17 83 pit
Takiir1711 77' 82
0717)7771130
Grease on its 556
aridness Total 960
\IIIAS 39.260
"howls 32730
urate 94.5
'ullide 745
ROMA
1 inie Begin
1200
Oi,o End
nyir 17
nest.
c.0
77)11
trent
re,tetL
retnit
not:1
neLhostem:
L
!norL
I)7plll.1))1,
El EFFLUENT
Ell INFLUENT
NII3 as N 603
FUN an Ni 925
7.7' pl7!"7
Iola' 00 l' 995
P0-1 as 17 70567
P 171,w,I cd as P 606
,k,,Polassiorn
Eds. Ciadminni 3.77
Ntittgieltte:
?AL Zio,t Ire):
LtVannefitan
,tt et S;i1 ce '077
711 Aluminum I 005
He- USeryllitim 1012
in. Calcium '7177,
o1717177
-
037
Vaine ype A, IL
not
nen L
tent L
mo
rot L.
i0711101on 'I- utzt1 lobc ' 100 tole. 'et toot 0645 717i„,.
UNPRESEREED. PRI:SERVE NUTRIEVT SAMPLLS WITH SUL FURICA CID TO pil<2
1„a71i Number 4611
1.14le Het:riser' 6,21i0 7
ime Rereiied 10 115 AS1
Reernied Ity 1171017
Dina Released AR
Dale Rennned 7,73,717
tompositesT, S.
Fri Lithium 717it2
Sample 'fype
Stn. SlanattAttnn nt27
710 1055
t SOO 9 UM 92',
Arsenic 'IntaI 1001
Se Selenium um I,
Itet Mercury 719,00 ne 17
Ba_13.teritim ttg 17
OtnernettInotate reetietties
Ornanopettophotus Pesticides
Itraticide's
Hase'NicutialecAcid Locaelable Orric;l:
FE 11 Diesel Range
Forgeable Organics t VOA bitule led
UPIICia.setine Ranee
OCSOICIC Ranee
inplittek inn

4 „ BASIN i _
REPORT TO: ARO
AT B1N
Other
Shipped by: Bus
COLLECTOR(•S):
ENVIRONMENTAL MANAGEMENT WATER QUALITY FIELD -LAB FORM (DM1)
PRIORITY SAMPLE TYPE
AMBIENT 0 QA STREAM © EFFLUENT
COMPLIANCE © CHAIN LAKE INFLUENT
OF CUSTODY
ERGENCY STUARY
Estimated BOD Ran
Seed: Yes El
25/25-65/40-130 or 100 plus STATION' LOCAT)ONa
Statlan 7
CCAL?OSN LC
10
12
19
20
COD Hlgh 340
Chlorinated: Yes ❑ No d REMARKS:
Date Begin (y
COD Low 335 mg/l
Colilorm: MF Fecal 31616 /itl0tnl
Colilorm: MF Total 31504 /100nr1
l 31615 /100m
p 31673 /100m
Volatile 505 mg
due: Suspended
Acidity to pH 8.3 435
Alkalinity to pH 8.3 415 mg/I
Polnt °t Conductarwt;e at 25 C`Wk>ater Temperature
d 10/S6
Salinity %
m/del)
Chloride 940
Ch1 a: Tri 32217
Chi a: Corr 32209
Date End
Pheophytln a 32213
Color;(pll ) 83
oehyde 71880
Grease and 011s 556
dness Total 900
ug/I
ug/1
Pt -Co
ADMI
ADM)
mg/1
pectilc Cond. 95 ullitos/cm2
11AS 38260 mg/I
32730 ag/1
Sulfide 74
1•
,Preclpltion (ln/day) Cloud Cover %
1•
Direction (De
Depth DM DB DBM
Stream Flow Sev
N1i3asN610
TKN as N 625
NO2 pins NO3 n
P: Total as P 661
PO4 as P 70507
P: Dlaaoived as P 666
rr Lab Use ONLY
Lab Number:
Date Received
Rec'd
DATA ENTRY BY;
DATE TED:
Value "1'ype
A 11 L
um;Tota11034 uti/1
Cu-Copper 1042
Nl-Nickel 1067
P4 Lased 1051
2tnc 1092
Calcium 916
n-Coto-ait 1037
Fe•Irnn 1045
p!! 4.5
d Del
GNXX
ug
eslunr 427 g
Na-Sodium 929
Arsenic:Total 1002
Se Selenium 1147
rcury 71900
Add llerbicldcs
Neutral3satrtctabta Organics
Acid Exlractabl
Purgeable. Organics (VOA bottlre r
Actdity
431 82243 82242
Air Temperature 10
rbidlty Severity Wlnd Velocity M/H 'ean Stream Depth it. Stream 4Nidtl

DIVISION OF WATER QUALITY
Chemimir) Laboratory Report t Water Qiiality
COLINT3 : GAS FON PRIORITY
RIVER BASIN jJ A4F3 EN1— OA
REPORT / 0 NIKO Regional 01I3re EA COMM IONCE n ("JAIN 0): ( US1 0131"
Other 1:11 EMERGENCY
COLLECTOR)S) LESLEY
Estimated DOD Kiel:get
Seed:
ci SA AIPL E T YPE
STREAM
Lil
LAKE
111 ESTUARY
Sini.ion loration: 1.1100 PERS CREEK AT 1037V 121
Chlorinated: Remas ks,
.110111.10.10.111110.1.
Bale Begin Ciyintaireidli
NC00050 I 10 970626
OD 3,10
0091 14ii6 140
Lott
olr(orur 0Irfecal oaI 1016
,ulifor 'Total 3 4
elitism tube Fecal 31615
'oliforin FeoI Slrep 31671
osidue iota
able 3
is 10
Retardate. Suspended 0
`o ati e 53
fixed 5, 0
pH 4 3
Acidity 11:p11454
Acielits 0 p 43
Alkalinity to p083115
Alkalinity to p I 4,
Turbidity
COMAI E NTS ::.
mat.
mat
matt,
1))0,nl
ml
1111
sisal
11101
mei
units
inelL
mst7L
ing1L
L
'T
ri LORI:JEN lr
Lab Number 7 W4642
Date Received 6/27/97
I Mit Reece. cd 10 05 A hl
Rcceieed I3 LINDY
Data Released AR
Date Repeated 12590
Date End CsalrridIt
Time Begirt
0230
Time End
Chloride 940 110 L
T6 32217
CIII ru Curt 3.2200
Ithenphytin 3221.7
Color -True 80
na. L.
(0101,. (pH ) 83 pHs
C,11.
Color: Oil 7.6 82 eva
anide 720 app. L
Fluoride 951
Formaldehyde 71380
..Gigase and Oils 356 11)0 L
Ilnidoess Total 900 mud.
01 1.1:111. (Sond 115 nAlloos or12
AS 38260 ingt
Phenols 12730 nal
Sulfate 945 int:A
Sulfide 745 me&
Boron
C01'11111111 1 00,11 lobo 11)1)1,111
cpu,- OM, DB, 01381
X
50
011
X
aloe fa pc - .0,11, 1 Cr,r,rp,roilr-T, S.
N117 as N 610 0.15
11)6
KN em N 625 0,9 nsgit
NO2 plus NO N 6,30 2 4 mad.
P. Total as P 665
PO4 ns P 70307
Disseaked as P STSA
0..36 trrySI,
trlySL,
rnteL
K-Potassilum rrigiL
CdsCadmium 1027 mist
Cr-Chronnum'Tool 1034 uu L
Cu- Copper 1042 tiat
Ni-Nickel 1067 ag/L
1'6-Ir114l55
7ss Zinc 1095.1 L
A. .17anadium
Ag- Silver 1077
Al- Aluminum I IC.3 ug
Be- Beryllium 1012
Calcium 915 mat
Co- Cobalt 1037 reurL
Fe- Iran 10457
Sample Tape
level I 1: 3:1 ire 7.
51- NIagnsstnin 027
htn-talatislialeax 1055 teal.
Na- Sodium 929 ingst.
Arsenic Frail 1002 ,, 1
Se- Selenium 1147 naL
I hi- Mercury 71900
ugiL
Bat3nrinin Sit
OnranochInsine Pesncides
Onsanophosphonts,
•N. cid I Icrbicide.s
13aSeSNe1,trale11. 0cid Estractable O. pante;
DieSed Range
Purgeable Organics O. OA bottle req`d)
HIT Gasoline Range
TPII.E1TEX Gasoline 101:0)1,-
11,,
toplank Ion

ENVIRONMENTAL MANAGEMENT WATER QUALITY FIELD -LAB FORM (DM1)
PORT TO: ARO FR
AT BM
Other
RRO WaRO IRO WSRO TS
Shipped by: Bu Courl4; 5ta11, Other
COLLECTORIS): L UL
Esti
Seed:
Stall
2
ed DOD Ra
25/25-65/40-130 or 100 plus
Yes E Ne Chlorinated: Yes 0 No
COD lllgh 34
COD Latxv 33:
Date Begin (y
1
PRIORITY
AMBIENT QA
©COMPLIANCE L.J CHAIN
OF CUSTODY
D EMERGENCY
STATION L
MARKS:
Time Begin
Date End
i
SAMPLE TYPE
STREAM
© LAKE
© ESTUARY
Time End
a ' Chl a: Trl 32217 ug/I
rng/I Cltl a: Corr 32209 ug/I
4
Fecal 31.616 /100m1 Pheolthytln a 32213 ug/I
or: True 80 Pt -Co
®I otttorm: cube Fecal 31615 /l0+Oatl' Color:(plI ) 83 ADMI
Crrlllotrm: Fecal Steep 31673 /100m1 or: pit 7.6 822 ADMI
Re:rldue; l
vtal 500 trtgfl Cyanide 720 ntg/I
© Volatile 505 mgg/1 Fnuorkte951tng/f
Flr:ed 510 to 11 rmaldehy de 71880 mg/1
Resldue: Suspended 530 mg/1 Grease and Oils 556 mg/I
2 Volatile 535 mg/1 Hardness Total900 mg/1
C.
Fixed 540 rng'1 Specltic Cond. 95 uMkosJt nt°
Acidity to pH 4.5 436
7 Alkalinity to pH 8.3 415
Alkalinity to pH 4.5 410 mg/I
OC 680
nductance at 25
Preclpltirn lltvday)
S 38260
Pkenole 32730
e 945 tng/I
ulllde 745
t �•
ud Cover %
400 1+
W1nd Dlrectlun (Deg)
For Lab Use LIN'
Lab Number:
Date Received:
© EFFLUENT Rec"d by:
© INFLUENT
DM 1)B DBM
NI/3asN610
TI{N as N 625
NO2 plus NO3 as N 630
F: T"oral as P 665
Pil4 as P '70507
P: Diasolued as P 666
Nl•Nlcl el lOt
Pb-Lead 105'
Zinc 1092
A7Sllver
1077
Al-Alunlit-non 1105
ylllurn 1012
Ca -Calcium 916
Co -Cobalt 1037
4
DATA ENTRY BY:
DATE REPORTED:
u
mg/1
C G GNXX
LI-Lithium '11;17 uq 1
Mg-Magneslum 927 mg/I
Mn-Manganese 1055 ug/I
Na-Sodium 929 nngr'1
Arsenic:Total 1002 ug/1
Se Setenlum 1147 ug/I
Fig -Mercury 71900 ug/I
lorine Pesticides
rospinorns Pesticides
Acid sierbicides
Base/ Neutral Extractable Organics
Acid Extractable {ltgaaa[ts
Purgeable 0rxlanica (VOA bottle r
ytnaplanttton
Acidity
pH 8.3
431 ^_ 82243 182242
urbldity Severity Wind Velocity
Air Temperature (C)

COUNT 5:
RIEER BASIN r
REPORT TO :
Other
COLLECTORTS)
Estimnird ROD linage:
Seed:
DIVISION OF WATER. QUALITY
Chemistry Labnotiory Report / Winer Quality
.1,117(1'i PRIORITY
At1616NT Ell OA
NIRO Regional Office CON1PLIANCE
1E61E5'
Station
NC000501 ID
BOD 310
COD High 340
COO Loss: 335
Coalmen 4,11 Fecal 31616
Coliloern IF Total 31504
Coliform Inbe Fecal 31615
Coliform Fecal Siren 31673
Residue Total 500
Volatile 505
Chlorinated:
Date Begin ty5immidd)
970626
5,6 reig7t
1110
1100m1
1100011
00161
Calm I
1319
Fixed 510
Residue Suspend
5,35
Fixed 540
pH 403
Acidity to pil 45 4011
Arida, to pll 3 .3435
Alkalinity to p1-1 5) 415
ma.71
ing.11
3333* L
rillitl
ingit
mgt
Alkalinity to pH 4 5 410 r1sta:1
10C 630
mg„:1
ilarrisidin 76 N141
9owl Esirs
Dvde End Tic) nn ni,71.1111
Chl a: Corr 32209
Pheophylia it 32213
Color, "Frue 3.0
Colot I pll t 83 pH,
Color. pll 7.6
Cyanide 720
Fluoride 95 I
Formaldehyde 71880
Grease and Oils 556
I tardorss loal 000
Specinc Triad 95
0144,0S 31260
P henols 32730
Sulfide. 745
Boron
014.01M I 00 tube
I
CHAIN OF CUSTODY
s-soil'ir FYN:
"
0 LAKE
Lil
FSTOAR
Simian loration: C3.050 134 RS ("11.61.51X A I" LOVIr 141.1AD
Remarks:
Time Begin
0145
Thug End
ug.T.
iigiL
mraiL
3119
mg:1
SI .10X.3.162
nueL
Depth 175
NIII as N610
'FEN oo N 625
NO2 plus NO3 IS N 630
P foal as P 665
P Dissolsed us 1 666
K-Paassuun
Cr-ChrontiunCroial 103-1
Cui Copper 1042
Mi.-Nickel 1067
1 cad10.5 I
,
Zinc 11192
--Vanadium
Be- Beryllium 1012
Ca- Calcium 916.
obali 03
Inds le- 43 1015
IT HA.' ENT
Ell INFLUENT
Yallie Type - A:11,1
3.6 mal_
muT
ingrt
10
sic
1„ah Number 7W4643
Receised 11.127,47
Time Receised 10 65 A 31
Ileceised 11, 115.1551
1:lia Released AR
Date Reported : 7C25.47
Composite- T.
Sample Type
Li -Lithium 1 132 us:
921
Aln-Manganese 1055 astil
Nar Sodium 924 3ng.11
Arsenic 7,1131 1002
Se- Selenium 1147
us
LIU L
I lg. Mercury 71900 L
Ba _Barium
1313
Organochlorine resins:ides
Cligarnpliosphonas Pesticides
Acid 1 lei bier:lea
Fla5e;Nernial4 Acid Eiorricialile Organics
1-1-111 Diesel Ranee
Purizeable Organics I VOA bode req`d
11711 Gasoline R,arge
11511113TE0 Gasoline Ranee
1116,6,0;40466

pr State of North Carolina
Department of Environment, Health and Natural Resources
Division of Water Quality
919 North Main Street Mooresville, North Carolina 28115
August 22, 1997
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Van M. Jones
CBP Resources - Gastonia Div.
5533 South York Road
Gastonia, North Carolina 28052
SUBJECT: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No. NC0005011
CBP Resources WWTP
Gaston County
Dear Mr. Jones:
This is to inform you that a review of your toxicity self -monitoring report form
for the month of June 1997 indicates a violation of the toxicity limitation specified in
your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the
conditions causing the effluent toxicity violations. Please be aware that North Carolina
General Statutes provide for assessment of civil penalties for violations of NPDES permit
limitations and requirements. If it would be helpful to discuss this situation or possible
solutions, please contact Mr. John Lesley with this office at [phone].
cc: Central Files
Aquatic Survey and Toxicology Unit
Sincerely,
J
Barbara S. Christian, P.G.
Acting Regional Supervisor

State of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
Jaynes B. Hunt, Jr., Governor
DIVISION OF WATER QUALITY
August 29, 1997.
Mr, Van Jones, Environmental Manager
CBP Resources, Inc.
5533 South York Road
Gastonia, North. Carolina 28052
Subject: Sampling Analysis Report
Compliance Sampling Inspection
CBP Resources WWTP
NPDES Permit No. NC000S011
Gaston County, NC
Dear Mr, Jones:.
Enclosed is a copy of the Sampling Analysis Report relative to the Compliance Sampling
Inspection conducted at the subject facility on June 26, 1997 by John Lesley of this Office.
Samples were collected by CBP personnel over a 24 hour period from June 25-26, 1997 for use in
BOD, TSS, ammonia as nitrogen, total nitrogen, and total phosphorous analyses, and a grab
sample of the discharge was collected by DWQ staff on. June 26 for oil and grease testing. Grab
samples were collected by DWQ personnel on June 26, 1997 for use in upstream and downstream
BOD, ammonia as nitrogen, total nitrogen, and total phosphorous analyses.
The sample analyses indicate that the facility is operating in compliance with NPDES
Permit effluent daily maximum discharge limitations. The report should be self-explanatory;
however, should you have any questions concerning this report, please do not hesitate to contact
me.
Sincerely,
John Le
Environmental Specialist 11
Enclosure
cc: Gaston County Health Department
919 North Main Street,
Mooresville, North Carolina 281 15
Voice 704-663-1699
FAX [phone]
An Equal Opportunity/Affirmative Action Employer
50% recycled/ 10% p6st-consumer paper

AIE,YTJCAL RESULTS SHEET
of Facility: CBP' Resources
rab: Composite: Yes
Sample Date(s): June 25-26, 1997
Sarnple Location: Effluent. Discharge
NPDES Permit No. NC0005O11
County: Gaston
HOD, rrt
COD: Hi
400 rng'1 (427 lbs)
henols,
COD: Low ran
s
Coliform; Fecal, #/100 nil
Bi
Total, #1100 m1
Peri Ash Free, m
Coliform Tube Fecal, MPN
N, rr► Invalid result'*
Coliform Tube Total, MPN �, m 'I Invalid result
Residue: Total, in
NO + NO,, m
rvalid
Volatile, mgd'l P©„ rn
Fixed,
P: Total, rng1l Invali
Resi
240 m "1 (2561bs) P: Dissolved, rn
Volatile, rn
Fixed,rn
- Silver, u
ble Solids, =nUl
pr
.u.
7.9 s,u, Ca - Calcium, 4/1
TOC, mCd - Cadmium, u
Turbidity, Co - Cobalt, u
Chloride, mg/I.
Cr - C
1.0 ma''l ' I.071bs1 Cu
Fe -
Pb
:T
AS
Ni - Nickel, ug/1
OS/cm Semivolatiles
4.0 mt'l VGC
T
Flow, MGD 0.I28 (cars. D
cites rr violation of NPDHS P
* Sample did not meet QA/QC criteri
Q
s a sa�rab

YTIC L RESULTS SHEET
Facility: CBP Resources
Yes Composite:
Sample Dat s a June 26, 1997
NPDES Permit No. N'C0005011
Sam • le Location: U • st
ate
e
Co
on
BGD,, mg/1 1.3
COD: High range,
COD: Low range, mg/1 S
Conform: Fecal, #/I00 m1
Biomass: Dry Weight,
Coliform: Total, #/100 ml
Biomass Pen. Ash Free, mg/1
Coliform Tube Fecal, NMPN
NH, - N, mg/1 0.15
Colifor® Tube Total, MPN
TKN, mg/I 0.9
Residue, Total, mg/1
NO, + N©,,
2.4
Volatile, mg/1
Poo mg/1
Fixed, mg11
P: Total, me 0.38
Su�nded m� P:
Volatile, mi Ag - Silver, u
Fixed, mg/1
Solids, m1/1
pH, s.u.
7..6 Ca - Calcium, ug/l
Cd - Cadrni
Timidity, Co - Cobalt, ug
Chloride, rng/1 Cr - Chromium, ug/1
Oil and Grease, mg/1 Cu - Copper, ug/1
Cyanide, ug/1
Fe - Iron, ug/1
Floaaa de, rng/1 Pb - Lead, ug/1
Total, mg/I Hg - Maury, ug/1
MBAS, mg#1 Ni - Nickel, ug/1
IOS/crn Semiv©latiles
mg/I V0C
iolation of NPDES Permit. Limitations

ANALYTICAL RESULTS SHEET
Grab: Yes* Composite:
NPDES Permit No. NC0005O11
COD: i L range, S.
COD: Low range, mstll S
brm: Fecal, #/100 ml
Total, #Iltl l Biomass Peri Ash Free, m,
Coliform Tube Fecal, MPN
Coliform Tube Total, NIPN
Residue: Total
Volatile, mgli PO4, m
P: Total, m 0.44
Residue: Su ended, rng/1 P: Dissol
Volatile, mg/l Ag Silver, u
able Solids, ml/1
au. 7.4 Ca - Calci
Turtaidity, Co - Cobalt, u
Oil and Grease, m
Cu - Coax, ugt'
Pb
ess: Total, mg/1
OS/cm
- Nickel
ivols
u
Dissolv
vac
Temperature, °C
mp
SC Highway 264

TEL:
Jul 21 ' 97 17:01 N©. 004 P.01
July 21, 1997
Mr. D. Rex Gleason, PE
Acting Regional Supervisor
Division of Water Quality
919 N Main Street
Mooresville, NC 28115
Subject; Notice of Recommendation for Enforcement
CAP Resources
Gaston County, NC
Gastonia. Divisson
CEP Resources, Inc.
to your July 8, 1997 NRommendation fo
dispute the facts that constitute the referenced violations, we
( the addition of four, 40 horsepower aerators at a coat of
lane and to eliminate the direct discharge to Crowdcrs creek
emendation for enforcement.
t.
w diligently toward a tie-in to the City of Gastonia's Mum
out discharge can be elirninAted. Our company also is committed to
necessary to remove the discharge from the creek as soon
7
We reaquest that your
may concentrate our cffprts Qa coup
working on plans to make t� ties -in.
0
Should there be any questions, pleas
brcememt be
the City. Presently, our
for your cousickaatiom
Vaa Int= or me.
• Gastonia, NC 28052 • 704-86+9941 • fax # 204•861-9252 • Di
1 N
ber

Mindy Horton
213 Salemview Rd.
- Gastonia, NC 28056
N.C. DEPT, OF
HNVIROMNIENT, HEALTH ,
?iATURAL RE5OURCES
APR 2 5 1997
MO OF Eltarkiik
000RISVIlit Wilt (*ICE
Mr Mike Landis
DEHNR Dept. AQ
919 N. Main St.
Mooresville, NC 28115
RE: CBP Resources
Gastonia Plant
Dear Mr. Landis:
Under the "Fredom of information Act" 1 am requesting that 1 be notified of any pending
new, modified, or renewal of any Air or Water permits that are to be issued to CBP
Resources, Gastonia Plant. 1, and our representatives, would like to have the opportunity
to make written andlor verbal comments as allowed by law.
When appropriate, please provide this information along with what options 1 have as a
citizen for input prior to permit issuance.
Please respond by letter that you have received this request 1 and the Community Action
Association appreciate your help.
Sincerely,
/
Mindy Horton
cc: Dir. of W Q
Jack Barbee
Robert Huffstetler
Tony McManus

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
March 19, 1997
Mr, Val IVI. Jones
CBP Resources, Inc.
5533 South York Road
Gastonia NC 28052
SUBJECT: Acknowledgment receipt letter
CBP Resources, Inc.
EiletNo, LV 96-030
NPDES No, NC00050I1
Gaston County
Dear Mr. Jones:
This is to acknowledge receipt of your check No.201204 in the amount of $4,734,30
received on March 19, 1997.
Thissatisfies ist full the civil assessment levied against the CBP Resources Inc., and this
case has been closed. Payment of this penalty in no way precludes future action by this
Division for additional violations of the NPDES Permit. If you have any questions please
call me at [phone] ext. 233.
Since/r7ely,
Robert L. Sledge, Supervisor
Enforcement/Compliance Group
cc: Mooresville Regional Offic
Enforcernent/Compliance File.,
Central Files
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

tate of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
February 4, 1997
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Val M. Jones
CBP Resources, Inc.
5533 South York Road
Gastonia NC 28052
SUBJECT: Assessment of Civil .Penalties for Violation() of
N.C. General Statute(s) 143-215.1
CBP Resources, Inc.
Gaston County
File No, LV 96-030
Permit Number NC00O5011
Dear Mr. Jones:
This letter transmits notice of a civil penalty assessed against CBP Resources, Inc. in the amount
of S4734.30, including 5284,3O in enforcement costs..
Attached is a copy of the assessment document explaining this penalty. This action was taken
under the authority vested in me by delegation pursuant to N.C,G.S. 143-215.6A(h). Any continuing
violation(s) may be the subject of a new enforcement action, including an additional penalty.
Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment shouuld be made directly to the order of the Department of Environment, Health,
and Natural Resources (do not include waiver f©rrn). Payment of the penalty will not
foreclose further enforcement action for any continuing or new violation(s),
Please submit payment to the attention of:
OR
Mr. Steve W. Tedder
Water Quality Section Chief
P.Q. Box 29535
Raleigh, North Carolina 27626-0535
P.U. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Submit a written request for remission or rrtitigatiun including a
detailed justification for such request:
A request for remission or mitigation is limited to consideration of the
reasonableness of the amount of the penalty and is not the proper procedure for
contesting the accuracy of any of the statements contained in the assessment
letter. Because a remission request forecloses the option of an administrative
hearing, such a request rnust be accompanied by a waiver of your right to an
administrative hearing and a stipulation that there are no factual or legal issues in
dispute. You must execute and return to this office the attached waiver and
stipulation form and a detailed statement which you believe establishes whether:
(a) one or more of the civil penalty assessment factors in G.S. 143B-
282.1(b) were wrongfully applied to the detriment of the petitioner:
(b) the violator promptly abated continuing environmental damage resulting
from the violation;
(c) the violation was inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violations;
(e) payment of the civilpenalty will prevent payment for the remaining
necessary remedial actions.
Please submit this information to the attention of:
Mr. Steve W, Tedder
Water Quality Section Chief
Division of Water Quality
P.O. Box 29535
Raleigh, North Carolina 27626-0535
OR
Submit a written request for an administrative hearing:
If you wish to contest any statement in this assessment letter, you must request
an administrative hearing. This request must be in the form of a written petition
to the Office of Administrative Hearings and must conform to Chapter 150B of
the North Carolina General Statutes, You must
File your original petition with the
Office of Administrative Hearings
P.O. Drawer 27447
Raleigh, North Carolina 27611-7447
and
or hand -deliver a copy of the petition to
Mr, Richard B. Whisnant
Registered Agent
Dept. of Environment, Health, and Natural Resources
P.O. Box 27687
Raleigh, North Carolina 27611-7687

Failure to exercise one of the options above within thirty days, as evidenced by a date
p (not a postmark) indicating when we received your response, will result in this matter
g referred to the AttorneyGeneral's Office with a request to initiate a civil action to collect
e penalty. Please be advised that additional assessments may be levied for future violations
hiclh occur after the review period of this assessment.
If you hay
26.
any questions please cozntac
Linda Forehand at (919) "733-5083
A. Preston Howard, Jr., RE.
Re onal Supervisor w/ attach:Ittelli
ts
o,mplia c nfor°cerrieaat File tt chrrentCent lFileswlattach nentsPubbc into ation Office w/acbx tits

STATE OF NORTH CAROLINA NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF GASTON
IN THE MATTER OF
CBP RESOURCES, INC.
FOR VIOLATIONS OF:
NPDES PERMIT NO. NC0005011
AND NORTH CAROLINA GENERAL
STATUTE 143-215.1(a)(6)
File No. LV 96-030
FINDINGS AND DECISIONS
AND ASSESSMENT OF
CIVIL PENALTIES
Acting pursuant to North Carolina General Statute (G.S.)
143-215.6A, I, A. Preston Howard, Jr., P.E., Director of the
Division of Water Quality (DWQ), make the following:
I. FINDINGS OF FACT:
A. CBP Resources, Inc. (the Company) is a corporation
organized and existing under the laws of the State of
North Carolina.
B. The Company operates a 0.257 MGD wastewater treatment
plant at Gastonia, which is located in Gaston County,
North Carolina,
C. The Company was issued NPDES Permit No. NC0005011 on
October 20, 1995, with an effective date of November 1,
1995 and an expiration date of September 30, 1996.
D. Said perMit contains the following relevant monthly
average and daily maximum effluent limitations:
Parameter Limitation Units
Monthly Average
Flow 0.257 MGD
NH3-N 140 lbs/day
Parameter
NH3-N
Fecal Coliform
Limitation Units
Daily Maximum
280 lbs/day
400 colonies/100 ml
NH3-N = Ammonia Nitrogen
E. Monthly self monitoring reports since July 1995 have
revealed exceedances of the above -cited permit effluent
limits as detailed in Attachment A.
F. Notices of Violation concerning the permit monthly
average limitations violations at the subject plant were
sent to the Company by DWQ's Mooresville Regional Office.

CBP Resources
Page Two
G. None of the above -cited exceedances of the permit
effluentlimitations were the result of a bypass or power
failure at the plant as defined by the permit.
H. A civil penalty assessment of $500.00 (Case No. LR 94-02)
was made for late submission of a monthly monitoring
report. An enforcement case was filed and civil
penalties were assessed against Carolina By -Products
(then known as Carolina and Southern Processing Company)
following a storage lagoon breech and subsequent fish
kill in Crowders Creek in July 1988.
1. The costs to the State of the enforcement procedures in
this matter totalled $ 284.30.
Based upon the above Findings of Fact, make the following:
II. CONCLUSIONS OF LAW:
A. The Company is a "person" within the meaning of G.S. 143-
212(4).
B. NPDES Permit No. NC0005011 is required by G.S. 143-215.1.
C. The effluent limitations contained in the subject permit
are terms, conditions, or requirements of said permits.
D. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on three (3) occasions during the
period July 1995 through June 1996 in the manner and to
the extent described in Attachment A, when the permittee
permitted waste to be discharged into the waters of the
State in violation of the monthly average permitted
effluent limit for Flow.
E. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on five (5) occasions during the
period July 1995 through June 1996 in the manner and to
the extent described in Attachment A, when the permittee
permitted waste to be discharged into the waters of the
State in violation of the monthly average permitted
effluent limit for NH3-N (Ammonia Nitrogen).

CBP Resources
Page Three
F.. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on eleven (11) occasions during the
period Jply 1995 through June 1996 in the manner and to
the extent described in Attachment A, when the permittee
permitted waste to be discharged into the waters of the
State in violation of the daily maximum permitted
effluent limit for NH3-N.
G. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on three (3) occasions during the
period July 1995 through June 1996 in the manner and to
the extent described in Attachment A, when the permittee
permitted waste to be discharged into the waters of the
State in violation of the daily maximum permitted
effluent limit for Fecal Coliform.
H. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 by failing to submit an Alternatives
Nutrient0' Analysis (for Total Nitrogen and Total
Phosphovis) by the June 30, 1996 due date.
1. General Statute 143-215.6A(a)(2) provides that a civil
penalty of not more than ten thousand dollars per
violation may be assessed against a person who violates
or fails'to act in accordance with the terms, conditions,
or requirements of a permit required by G.S. 143-215.1.
3. The State's enforcement costs in this matter may be
assessed against the Company pursuant to G.S. 143-
215.3(a)(9) and G.S. 143B-282.1(b)(8).
K. The Director, Division of Water Quality, pursuant to
delegation provided for by G.S. 143-215.6A(h), has the
authority to assess civil penalties.
Based upon the above Findings of Fact and Conclusions of Law
I make the following:
III. DECISION:
Accordingly, the Company is hereby assessed a civil penalty
of:
$ .250 - b . 5) For of the three (3) subject violations
of G.S. 43-215.1(a)(6) and NPDES Permit No.
NC0005011, by discharging waste into the waters
of the State in violation of the monthly
average permit effluent limit for Flow.

CBP Resources
Page Four
$
For of the five (5) subject violations of
G.S. 143-215.1(a)(6) and NPDES Permit No.
NO0005011, by discharging waste into the waters
of the State in violation of the monthly
average permit limit for NI-13-N.
For 7 of the eleven (11) subject violations
of G.S. 143-215.1(a)(6) and NPDES Permit No.
NC0005011, by discharging waste into the waters
of the State in violation of the daily maximum
permit effluent limit for NH3-N.
750. Po For 3 of the three (3) subject violations
37(25 • ev
$ 4495-4. Iry
of G.S. 143-215.1(a)(6) and NPDES Permit No.
NO0005011, by discharging waste into the waters
of the State in violation of the daily maximum
permit effluent limit for Fecal Coliform.
For failure to submit an alternatives nutrient
analysis as required by NPDES Permit No.
NC0005011.
TOTAL CIVIL PENALTY, which is ';‘'.‘ Z40 percent of
the maximum penalty authorized by G.S. 143-
215.6A.
284.30 Enforcement costs
$ c7 g ell. 3 0 TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of
the penalty I have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G.S. 143B-
282.1(b), which are:
(1) The degree and extent of harm to the natural resources of
the State, to the public health, or to private property
resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or quality
or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;

CEP Resources
Page Five
(6) Whether the violations were committed willfully or
intentionally;
(7)
(8)
The prior record of the violator in complying or failing
to comply with programs over which the Environmental
Management Commission has regulatory authority; and
The cost to the State of the enforcement procedures,
A. Preston Howard, Jr., P.E., Director
Division of Water Quality

ATTACHMENT A
Violator. Carolina By -Products WWTP
NPDES Permit No. NC0005O11
Flow
December 1995
February 1996
March 1996
NH3-NN
January 1996
February 1996
March 1996
April 1996
June 1996
NH,-N
January 22, 1996
February 1, 1996
March 6, 1996
March 29, 1996
March 27, 1996
April 4, 1996
April 19, 1996
June 6, 1996
June 14, 1996
June 21, 1996
June 28,r 1996
MONTHLY AVERAGE LIMITS VIOLATIONS,
PERMIT LIMIT = 0.257 MGD
0.2580
0.2750
0.3450
PERMIT LIMIT = 149 lbs/day
232.8 *
145.0
429.0
273.0
460.0
DAILY MAXIMUM LIMITS VIOLATIONS
PERMIT LIMIT = 280 lbs/da
327.0
294.7
298.0
867.0
444.8
415.0 *
315.0
452.6
646.0
336.0
406.0 *
Fecal Colifarm PERMIT LIMIT = 409 coloniesd1©9
March 13, 1996 TNTC ("too numerous to count")t
April 11, 1996 TNTC
June 21, 1996 TNTC
t In accordance with North Carolina Administrative Code T15A: 02B
.0506(b)(3)(I), the reporting of "too numerous to count" (TNTC) as
a fecal coliform value will constitute a violation.
PERMIT CONDITION VIOLATION
Failure to submit an alternatives analysis nutrient study by
June 30, 1996 as required by NPDES Permit No. NC0085O11.
* Assessed

STATE OF NORTH CAROLINA
COUNTY OF
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST
PERMIT NO.
ENVIRONMENTAL MANAGEMENT
COMMISSION
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
FILE NO„
Having been assessed civil penalties totalling for
violation(s) as set forth in the assessment document of the Director of the Division of Water Quality
dated, , the undersigned, desiring to seek remission of the civil
penalties, does hereby waive the right to an administrative hearing in the above -stated matter and does
stipulate that the facts are as alleged in the assessment document.
This the day of , 19
SI NATU
ADDRESS
TELEPHONE

DIVISION OF WATER QUALITY
September 3 1996
MEMO
FROM: B. Keith Overcas
THROUGH: D. Rex Gleason
PREPARED BY: Patricia D. Beam /13
SUBJECT: Enforcement Action
Fast Track (LV)
Violation of N.C. General Statute
143-215.1(a)(6)
and NPDES Permit No. NC0005011
CBP Resources WWTP
Gaston County, NC
TO: Dianne Williams Wilburn
Attached please find one (1) copy of the subject enforcement
document. If you have any questions, please contact either Rex or
Patricia.
Attachments
PDB

STATE OF NORTH CAROLINA
COUNTY OF GASTON
IN THE MATTER OF
CBP RESOURCES, INC.
FOR VIOLATIONS OF:
NPDES PERMIT NO. NC0005011
AND NORTH CAROLINA GENERAL
STATUTE 143-215.1(a)(6)
NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
File No. LV
FINDINGS AND DECISIONS
AND ASSESSMENT OF
CIVIL PENALTIES
Acting pursuant to North Carolina General Statute (G.S.)
143-215.6A, I, A. Preston Howard, Jr., P.E., Director of the
Division of Water Quality (DWQ), make the following:
I. FINDINGS OF FACT:
A. CBP Resources, Inc. (the Company) is a corporation
organized and existing under the laws of the State of
North Carolina.
The Company operates a 0.257 MGD wastewater treatment
plant at Gastonia, which is located in Gaston County,
North Carolina.
C. The Company
October 20,
1995 and an
was issued NPDES Permit No. NC000501.1 on
1995, with an effective date of November
expiration date of September 30, 1996.
D. Said permit contains the following relevant monthly
average and daily maximum effluent limitations:
Parameter
Flow
NH3-N
Parameter
NH3-N
Fecal Coliform
Limitation
Monthly Average
0.257
140
Li
Dal
ation
Maximum
280
400
Units
MGD
lbs/day
Units
lbs/day
colonies/100 ml
NH3-N = Ammonia Nitrogen
Monthly self monitoring reports since July 1995 have
revealed exceedances of the above -cited permit effluent
limits as detailed in Attachment A.
Notices of Violation concerning the permit monthly
average limitations violations at the subject plant were
sent to the Company by DWQ's Mooresville Regional Office.

CEP Resources
Page Two
G. None of the above -cited exceedances of the permit
effluent` limitations were the result of a bypass or power
failure at the plant as defined by the permit.
A civil penalty assessment of $500.00 (Case No. LR 94-02)
was made for late submission of a monthly monitoring
report. An enforcement case was filed and civil
penalties were assessed against Carolina By -Products
(then known as Carolina and Southern Processing Company)
following a storage lagoon breech and subsequent fish
kill in Crowders Creek in July 1988.
I. The costs to the State of the enforcement procedures in
this matter totalled $ 284.30.
Based upon the above Findings of Fact, 1 make the following:.
II. CONCLUSIONS OF LAN:
A. The Company is a "person" within the meaning of G.S. 143-
212(4).
B. NPDES Permit No. NC0005011 is required by G.S. 143-215.1.
C. The effluent limitations contained in the subject permit
are terms, conditions, or requirements of said permits..
D. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on three (3) occasions during the
period July 1995 through June 1996 in the manner and to
the extent described in Attachment A, when the permittee
permitted waste to be discharged into the waters of the
State in violation of the monthly average permitted
effluent limit for Flow.
E. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on five (5) occasions during the
period July 1995 through June 1996 in the manner and to
the extent described in Attachment A, when the permittee
permitted waste to be discharged into the waters of the
State in violation of the monthly average permitted
effluent limit for Nil3-N (Ammonia Nitrogen).

CBP Resources
Page Three
F.. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit N9. NC0005O11 on eleven (11) occasions during the
period Jv1y 1995 through June 1996 in the manner and to
the extent described in Attachment A, when the permittee
permitted waste to be discharged into the waters of the
State in violation of the daily maximum permitted
effluent limit for NHa-N.
G. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 on three (3) occasions during the
period July 1995 through June 1996 in the manner and to
the extent described in Attachment A, when the permittee
permitted waste to be discharged into the waters of the
State in violation of the daily maximum permitted
effluent limit for Fecal Coliform.
H. The Company violated G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0005011 by failing to submit an Alternatives
Nutrient Analysis (for Total Nitrogen and Total
PhosphotQs) by the June 30, 1996 due date.
I. General. Statute 143-215.6A(a)(2) provides that a civil
penalty of not more than ten thousand dollars per
violation may be assessed against a person who violates
or fails'to act in accordance with the terms, conditions,
or requirements of a permit required by G.S. 143-215.1.
The State's enforcement costs in this matter may be
assessed against the Company pursuant to G.S. 143-
215.3(a)(9) and G.S. 143B-282.1(b)(8).
The Director, Division of Water Quality, pursuant to
delegation provided for by G.S. 143-215.6A(h), has the
authority to assess civil penalties.
Based upon the above Findings of Fact and Conclusions of Law
I make the following:
III. DECISION:
Accordingly, the Company is hereby assessed a civil penalty
of:
For of the three (3) subject violations
of G.S. 143-215.1(a)(6) and NPDES Permit No.
NC0005011, by discharging waste into the waters
of the State in violation of the monthly
average permit effluent limit for Flow.

CBP Resources
Page Four
2
For of the five (5) subject violations of
G.S. 143-215.1(a)(6) and NPDES Permit No.
NC0005011, by discharging waste into the waters
of the State in violation of the monthly
average permit limit for NH3-N.
For of the eleven (11) subject violations
of G.S. 143-215.1(a)(6) and NPDES Permit No.
NC0005011, by discharging waste into the waters
of the State in violation of the daily maximum
permit effluent limit for NH3-N.
For of the three (3) subject violations
of G.S. 143-215.1(a)(6) and NPDES Permit No.
NC0005011, by discharging waste into the waters
of the State in violation of the daily maximum
permit effluent limit for Fecal Coiiform.
For failure to submit an alternatives nutrient
analysis as required by NPDES Permit No.
NC0005011
TOTAL CIVIL PENALTY, which is percent of
the maximum penalty authorized by G.S. 143-
215.6A.
Enforcement costs
TOTAL. ANG DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of
the penalty I have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G.S. 143B-
282.1(b), which are:
(1) The degree and extent of harm to the natural resources of
the State, to the public health, or to private property
resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or quality
or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;

CSP Resources
Page Five
Whe her the violations were co
intenti nally°
The prior record ;of the violator i complying or f iling`
to comply with Programs over which the En.ro rental
Management Co u ission has regniatorY authority;and
The cost tc the State of the
(Date
A. Preston Howard
Division of Water Qual

ATTACHMENT A
Violator: Carolina By -Products WWTP
NPDES Permit No. NC0005011
Flow
December 1995
February 1996
March 1996
NH3-N
January 1996
February 1996
March 1996
April 1996
June 1996
MONTHLY AVERAGE LIMITS VIOLATIONS
PERMIT LIMIT = 0.257 MGD
0.2580
0.2750
0.3450
PERMIT LIMIT = 140 lbs/day
232.8
145.0
429.0
273.0
460.0
DAILY MAXIMUM LIMITS VIOLATIONS
NH3-N PERMIT LIMIT = 280 lbs/day
January 22, 1996
February 1, 1996
March 6, 1996
March 20, 1996
March 27, 1996
April 4, 1996
April 19, 1996
June 6, 1996
June 14, 1996
June 21, 1996
June 28, 1996
327.0
294.7
298.0
867.0
444.8
415.0
315.0
452.6
646.0
336.0
406.0
Fecal Coliform PERMIT LIMIT = 400 colonies/100
March 13, 1996
April 11, 1996
June 21, 1996
TNTC ("too numerous to count")t
TNTC
TNTC
t In accordance with North Carolina Administrative Code T15A: 02B
.0506(b)(3)(I), the reporting of "too numerous to count" (TNTC) as
a fecal coliform value will constitute a violation.
PERMIT CONDITION VIOLATION
Failure to submit an alternatives analysis nutrient study by
June 30, 1996 as required by NPDES Permit No. NC0005011.

Type:
Violator:
Address:
ENORCEMENT CASE ASSESSME
(LV) Limits Violations
CBP Resources, Inc.
5533 South York Road
Gastonia, N.C. 28052
FACTORS
Registered Agent: United States Corporation Company
327 Hillsborough Street
Raleigh, N.G. 27602
Regional Office: Mooresville
1. The degree and extent of harm to the natural resources of the
State, to the public health, or to private property resulting
from the violations:
No harm has been measured or quantified. NPDES Permit limit
violations have the potential to affect the designated uses of
the receiving stream (i.e. recreation, agriculture, water
supply, etc.) and may cause water quality standards to be
exceeded.
2. The duration and gravity of the violations:
Effluent limits violations occurred from July 1995 through
June 1996. Fifteen of the twenty-two limits violations were
Technical Review Criteria violations.
3. The, effect on ground or surface water quantity or quality or
on 'air quality:
Adverse effects to air quality have been documented through
complaints filed from residents near CBP Resources. It is
possible that the limits violations could impact surface water
quality.
4. The cost of rectifying the damage:
No environmental damage has been established.
5. The amount of money saved by noncompliance:
Money may have been saved by not providing adequate operation
and maintenance of the facility or by not constructing
additional facilities to maintain compliance.
S. Whether the violations were committed willfully or
intentionally:
There is no evidence to suggest that the violations were
committed intentionally.
7. The prior record of the violator in complying or failing to
comply with programs over which the Environmental Management
Commission has regulatory authority:

CBP Resources
Assessent Factors
Page Two
A civil penalty assessment of $500.00 (Case No. LR 94-02)
was made for late submission of a monthly monitoring report.
An enforcement case was filed and a civil penalty assessed
against Carolina By -Products (then known as Carolina and
Southern Processing Company) following a storage lagoon breech
and subsequent fish kill in Crowders Creek in July 1988.
The cost to the State of the enforcement procedures:
6.0 hours by investigator for investigating and
drafting report @ $16.85/hour
1 hour by Water Quality Regional Supervisor
for review @ $36.52
$ 101.10
36.52
1 hour by Regional Supervisor for review
$35.75 $ 35.75
1 hour for clerical support @ $10.93 $ 10.93
Central Office Review and Processing:
TOTAL COST OF THE ENFORCEMENT PROCEDURES:
$ 100.00
$ 284.3©
9. Type of violator and general nature of business (i.e.
individual vs. large corporation):
The company operates a rendering and recycling plant. Animal
by-products (obtained from meat packing, poultry processing
plants, etc.) are used in the production of animal feed
ingredients and animal fats.
10. Violators degree of cooperation (including efforts to prevent
or restore) or recalcitrance:
The violator has responded to the Notice of Recommendation for
Enforcement. The response addresses the options of an upgrade
of the wastewater treatment plant in an effort to prevent
future violations or connection to the City of Gastonia POTW.
A suspension of the nutrient analysis requirement has also
been requested by the violator.
11. Mitigating Circumstances:
None that we are aware.
12. Assessment Factors:
a) IWC: 61%
b) Receiving Stream: Crowders Creek
c) SOC/JOC status/negotiations: N/A
d) Copy of MP Screen: Attached.
e) Copy of Limits Page in Permit: Attached.
f) Damage: None Known.

best
CERTIF0 PAGE
I certify that the information in this report is true to the
of my knowledge. All violations of self -monitoring dato have
verified by hard copy review of the monthly r+ports and the
appropriate pe ,it.
S gnature of Princi sl Investigator
Date:

A. ( ). EFFLUENT LIl! T'AT1ONS AND MONITORING REQUIREMENTS FINAL
During the period beginning on the effective date of the prmlt and lasting until expiration
outfall(s) serial number 411. Such discharges shall be limited and monitored by the permittee as s
Effluent. Charact
Mc
Flow
SOD, 5 Day, 20 °C
NH3 es N
Dissolved Oxygen
Total Suspended Residue
Fecal Coliform (geometric mean)
Oil and Grease
Total Nitrogen (NO2+NO3+TKN)
Total Phosphorus
Temperature, °C
Chronic Toxicity"
Dlscharue . Limitations
Units (specify)
Avg. Daily .. Met
Pettit No. NC0005411
orizcd to discharge from
w:
Monitoring
Measurement
Mon. Ave. Daily Mazi, Frequency
0.257 MGM Continuous
340 680 158 mg/I 317 mg/I Weekly
140 280 Weekly
Weekty
420 * 840 Weekty
1 400 /100 mi Weekly
200 400 Weekly
Quarterly
Quarterly
Weekly
Quarterly
I.'. y..
ulratrrtents
piar
Recorder
Composite
Composite
Grab
Composite
Grab
Grab
Composite
Composite
Grab
Composite
I or E
E
EU,D
E
E
E
E,
E.
E,U,D
E
* Sample loc rtions: E - Effluent, I Influent, U - Upstream at. US Hwy 321, it - Downstream at SC Hwy 654. Upstream and Downstream
monitoring is to be conducted three times per week during June, July, August, and. September, and once per week during the rest of the year.
**Chronic Toxicity (Ceriodaphnia) P/F at 3%, August, November, February, May, See Part III, Condition E.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored three times per week at the effl
by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
uent

CC F°L :AN C °ALUT''T IDE.. ANALYSIS E `
i r',a::xC
H
IT
/08
PER 1:T—- CO 050ii
TY— CDP REE URCES
I1 1--GASTONIA
i1 330
1?L: AGE
MAXIMUM
MINIMUM
1�1l IT
E. 0
-075
.0750
PIPE— —001 REPORT PERIi
GASTONIA D1: DESID
REGION/COUNT
11 00530
F /TEE NEI FEC
46, e
L. F
5', T4
Ft
6 , D
20
DAY.
f
07
—03
GASTON
9
LC%--.—E
00 TCF.a31
DO RIr P'
40
23.00
4,x 00
.40
MG/L 'A -:. FAT
50

L
96
C" :'F ° F s
TONI
E
N111101 7.200
5
F
9
AN
TIRE
u
1
9001 R -PORT PC°<; l 9;i (1 606
F:N 1#E 3 [:a`. 1 FF Ft [
REG 1 0 21.11UN P Y 9 903
1
GASTON

EFFLUENT
A
AUG 12 icir
NPDES PERMIT NO. ,VC Q 00 S6I/
DISCHARGE NO, O 4 I Mo:
FACILITY NAME G+C5'1 ' I'us©u r CLASS
/77v4hAs
e.ra.rc,G� (2)
OPERATOR IN RESPONSIBLE CHAR
CERTIFIED LABORATORIES (1)
CHECK BOX IF ORC HAS CHANGED
Mail ORIGINAL and ONE COPY to:
ATTN: CENTRAL PILES
DLY, OF LNYTIONMENTAL MANAGEMENT
DEAMR
P 0. * X 29S3S
GS
(Si ATCR OF OF TOR IN RESPf' NSi13i E Ci ARGE,"
BY THIS 51 G 4 TURE, I CERTIFY THAT TH,15 REPORT IS
ACCURATE AND COMPLETE TO THE HEST 0E MY KNOWLEDGE.
DEM Form MR-1 (12193)

CM E JN 2 b 199
EFFLUENT
DISCHARGE NO co / MO
NPDES PERMIT NO. %/CAAO
FACILITY NAME C f akrc -S-°-
OPERATOR IN RESPONSIBLE CHARGE (ORC
CERTIFIED LABORATORIES (I) d
cAr
CHECK BOX IF ORC HAS C ANGEDN.0
ENVIRONM
Mail ORIGINAL and ONE COPYr'.rU L
ATTN: CENTIUU. FILES
Dry. OF ENVIRONMENTAL MANAGEaMENT� `
DEH$R
P.O. DOX 2,515
OFPERSON
;T, HEALTH;
RESOURCES
(SIGNATURE OP OPERATOR IN RES
1996 SY THIS SIGNATURE,1 CERTIFY THAT THIS REPORT
ACCURATE AND COMPLE:7E TO THE BEST OF MY KNOWLEDGE.
CLASS - ,: CO
J artit S G^
(2) r` . ! ° r9 r ✓,
G SAMP
NS
DATE

UN
EFFLT E
NPDES RMITNAME
. �? 0FACILITY
OPERATOR IN RESPONSIBLE CHARGE)ORC
CERTIFIED LABORATORIES (1) .»
CHECK BOX IF ORC HAS CHANGED
N.C. 1)
Mail ORIGINAL and ONEteermtwENT. HEAL'
ATTN:CENTTRALFILLS & NATURAL F: "©UJRCIES
DIY. OF ENVIRONMENTAL MANAGEMEWr
DEHNR
PA. BOX»
GH. Ii1C
JUN 12
ON(S) COI
(S1GNATL11'tE QF OPERATO
96 BY THIS SIGNATURE, 1 CERTIFY THAT THIS REPORT IS
ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE.
DA
DE3.4 Form NOW (12/93)

CMS
EFFLUENT
NPDES PERM NO., 4/1 00 I DISCHARGE NO..00l
PACILI-IY NAME CZ, s cuss
OPERATOR IN RESPONSIBLE CHARGE (ORC)a'. Ydr.1.S
CERTIFIED LABORATORIES (1) ,. (2)
CHECK BOX IF ORC HAS CHANGED PERSON
Mail ORIGINAL and ONE COPY u e
AT17. CENTRAL PILES
DIV. OF ENVIRONMENTAL MANAGEMENT
DERNR
RA. BOX MS
NC
A
A
s
RATO
APR 6 Mg
TIFF THAT TREPORT IS
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DATE
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NPDES PERMIT NO,9 C E� a► " DISCHARGE NO. 0 4
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Detellt aY THIS IGIFY THAT MS REPORT IS
ROI 19535 ACCURATE AND COMPIXTE TO THE REST OF MY KNOWLEDGE.
GH, NC
DEM Form. MR-1

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9
Dl Form MR-1 (1293)

Part HT Perncait No. NC5011
G. This discharge has been targeted for removal from the Crowders Creek drainage basin
through connection to the City of Gastonia Crowders Creek Wastewater Treatment
Facilities. Upon the demonstration of compliance with NPDES Permit NC0074268 by the
Crowders Creek Wastewater Treatment Facility to the satisfaction of the Director of
Environmental Management and the availability of a sewer connection to the Crowders
Creek system as the most environmentally sound alternative of the reasonably cost-effective
alternatives, this discharge shall be eliminated within one hundred eighty (180) days of
notification by the Division,
' CBP Resources shall submit an alternatives analysis showing present values costs
associated with meeting monthly nutrient limits of 1 mgfi (Total Phosphorus) and 6 mg/1
(Total Nitrogen) versus the present value costs associated with connection of this discharge
to the City of Gastonia's Crowders Creek WWTP. This analysis shall be due to the
Division by June 30, 1996. The original and one copy should be mailed to:
DEHNRfDEM - WQ Section
Permits and Engineering Unit
P.O. Box 29535
Raleigh, North Carolina 27626-0535

TEL:
Hug 1y"fib 1b;1J NO All( r.u4
Mr. D. Rex Gieu P.E.
Regional W
Dtviskm ofWaterQualuy
919 N.Msat Street
Mee, N.C. 281.15
Dear Rem:
This will aolcuowlcdgc our Ax 19, 1996 receipt
Kew Overcash to E.R. Olhardsu8 with this Company. Abo this
foam with Mike Parker on August 28, 1996 (hiring wb ith 1 advised Mike) that a
response would be faxed to you on August 29, 1996 aurl the original waned cm the came
day
5533 5. Stal RC. • Gastonia. NC 25052
•
• Din t [ Nanber.

TEL:
Aug 29'96 16:15 No.017 P.05
.gficrEngineering Company, Inc.
ConsulOng Environmental Engineers
cr.--lalizingb h4 Dignrgrt and Operation of Weber Pollution Control grotto,
Auzust 27, 1996
Mr. Rex Gleason, P.E.
Regional Supervisor
North Carolina Department of Environment,
Health and Natural Resources
Division of Environmental Management
Water Quality Section
P. O. Box 29535
Raleigh, North Carolina 27626-0535
SUBJECT: CBP RESOURCES, GASTONIA, NORTH CAROLINA
WASTEWATER TREATMENT SYSTEM UPGRADE
Dear Mr. Gleason:
CRP Resources in Gastonia, North Carolina has retained Reid Engineering
Company to develop a concept design and Implementation Schedule for
upgrading and expanding the existing CBI' Resources wastewater treatment
system in Gastonia, North Carolina. This upgrade plan and schedule will be
completed in the following phases:
Phase I: Design and install an upgrade to the existing wastewater treatment
system to maintain compliance with the misting NPDES permit
limitations at the present rendering plant maximum daily
production capacity of 9,000,000# of raw material/week.
Phase II: Design and install an exparmion to the upgraded wastewater
treatment system to accommodate an expansion in rendering plant
production capacity to 15,000,000# raw materlal/week while
maintaining compliance with 'westing NPDES permit limitations.

n,P
Deepsrnne t of went
and Natural Resources
Phase EL sign and install an upgrade to the expanded wastewater
treatment tern to provide nutrient removal capability tea comply
with proposed new NPDES permit limitations of 1 mg/L Total
Phosphorous and 4 mgfL Total Nitrogen.
Reid Engineering Company has been authorized to proceed with Phase t
engineering services by CBP Resources as required to upgrade the existing
wastewater treatment system to comply with existing NPDES permit
liritations. The fallowing alternatives are presently being evaluated by Reid
Engineering Company to determine a concept design for the Phase I upgrade
to improve existing wastewater treatment system performance:
1. The installation of a npretreatment system will be
necessary to reduce the poncentrations contained in the
washdown and drainage wastewater discharged from the rendering plant
into the existing Activated Sludge Aeration Lagoon #1. These proposed
wastewater pretreatment system improvements include the installation
and operation of a new first stage Gravity Skimmer Basin for removal of
free grease and settleable solids and a new second stage Dissolved Air
Flotation Cell to provide BOD, TSS and TIN removal by chemical.
coagulation, flocculation and flotation.
The installation of a new Anaerobic Basin is being considered to provide
third stage wastewaterpretreatment aad 7 day hydraulic flow
egiinli7ation of blended raw condensate wastewater and pretreated
washdown drainage wastewater upstream of existing Activated Sludge
Aeration Lagoon #1. This anaerobic basin would be operated to
provide additional pretreatment of BOD and more uniform 7 day, 24
hour pollutant loading and hydraulic loading on the downstream existing
Activated Sludge Aeration Lagoon #1.
The feasibility of +;ai rting misting Activatcd Sludgc Aeration Lagoon
#1 into a aew Anoiic Lagoon designed to provide combined wastewater

TEL.
Aug 29'96 16:16 No1.7 P.07
Mr. Rex Gl as aer, P_E.
North Carolina Departiuent of Environment
Health and Natural Resources
August 27, 1996
Page 3
pretreatment and 7 day hydraulic egtaallz lion upstrean from a new
Activated Sludge Aeration Basin will also be evaluated. Existing Lagoon
#1 can be converted into anoxic lagoon providing combined
carbonaceous BOD removal, 7 day hydraulic flow equatiratian And
deaitrification of nitrate contaiaed in treated wastewater recycled from
the final clarifier discharge back to Lagoon #1.
The feasibility of installing a new s c ud stage Activated Sludge
Nitrification Basin designed to provide year around high efficiency
ammonia nitrogen removal is being evaluated. This new Activated
Sludge Aeration Basin would also be designed to provide partial nitrate
removal by biological denitrification.
Installation of modifications or additions to the existing final clarification
system will be evaluated to provide increased final clarification capacity
for activated sludge solids contained in the miTrd liquor discharged from
existing Activated Sludge Aeration Lagoon #1
Rid Engineering Company proposcs to complete an evaluation of Phase
cwatcr treatment system upgrade alternatives and present concept design
endations to CBP Resources by the end of September 1996. A Phase
ct Implementation. Schedule will be determined at that time after
cceptance of a final concept design by CBS' Resources. A Phase I treatment
system upgrade Concept Design and Implementation Schedule will then be
submitted to the State of North Carolina Department of Environment, Health
and Natural ltesaurces (U1 .HNR) in October 1996.
Phase 11 engineering services to be completed by Reid Engineering
Company will include the evaluation of nutrient removal processes such as
physical/chemical removal of phosphorous, biological phosphorous removal and
nitrogen removal by n itr€fication/dcnit ifscation. The feasibility of instA11 ing
these nutrient removal process in the Phase II treatment system
upgrade/expansion will be evaluated to determine the potential capital and

6 Revised 9/19/95
D EMIAQ\ W PDATA\COUNTIIES1
NORTH CAROLINA DIVISION OF AIR QUALITY
Name
CBP Resources, Gastonia Div
Con
Van Jones
Type Action: CI X
Air Program Status:
Action Requested. By:
Last In p. Dat
Permit 369tiR 13
Data Tracking:
Recommendations:
on
Continue Surveillance
jirecti+ n c Facility:.
TS
Quality Action Ref
cation
3 South York. Road
ronia, Gaston Count
Telephone
704-864-9941
0
Ads /Phone
ASTON\OOO26191Q}32(.Ct6i
Reg/Co. Prem
03/36/00026
Change to:
Action Date 03/20/97 Next
Issued 9/19/96
Rec'd Date
p.Date Ongoing
Surveillance
Expires 6/30/97
n TOXLB D COMPLAIN Di -STEPS Actio
Signature:
Ronald E. Slack
Number:
This facility a rendering plant that mostly processes chicken blood and feathers as raw material
for dog food manufacturers: It is located approximately V mile north of the NC/SC state line on Highway
321 (5533 South York Road) in southern Gaston County, North Carolina,
On Thursday, March 20, 1997, John Lesley from Water Quality, and I, Ronald Slack, from Air
Quality, arrived at CBP Resources at approximately 1120 hours. The sky was cloudy. We conducted a
surveillance along the standard route„ At 1130 hours, we detected a slight odor (level 1) on CR Wood
Road. The same odor was near the bridge on Thompson Road (level 1) as well as at the end of Salem
View Road (level 2).
io
Date:.

CBP Resources, Inc.
March 19, 1997
Page 2
We proceeded to CBP Resources to check the condition of the lagoons. An odor up to level 4 was
located at the end of the lagoon nearest the plant. On the far side of the lagoon the odor level was level
3. Compared to our March 3, 1997 observations, the odor level was less and the water level in the largest
lagoon was about 12 inches lower.
From the lagoons, we went to the plant. The feather cooker was not operating. Maintenance was
being conducted on the dryer fan. The blood plant was operating with emissions going through the bio-filter.
Only wood odors were observed at the bio-filter. The piping and nozzles for the new sprinkler system had
been installed but the system was not operational. The old system still had to be used. The plant appeared
to be cleaner than usual as noted by Mr, Lesley and myself. Van Jones explained that the plant controlled
three sources of wastewater that enabled the plant to reduce water flowing into the lagoons by about 70,000
gallons per day. This savings could help increase retention time by one day and hopefully reduce odors
faster. The storage yard had about 4 trailer loads of feathers with minor yard odors from these feathers.
Based on our observations, the odors observed off the facility were coming from the lagoons.
RES:res

ERATIONIS BRANCH - WO Fax:[phone] Mar 18 '97 15:01 P.01/03
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water (Duality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
WATER i UALITY SECTION
COMPLL NCE ROUP
FAX NUMBER: ' 1 715-6048
TFLF,COPY TO:
FAX NUMBER:_.
FROM; Bob Slcdgc
PHONE: [phone], c)Lteusi 233
NUMBER OF PAGES INCLUDI'N'G THIS SHEET: 3
COMMENTS: . / h
999
Pools IS
P,O. Box 29535, Raleigh, North Carolina 27626-0535 Tet :} hcne 919-733-5083 FAX [phone]
An Equal opportunity Affirmative Action Employer 50% recycled/ 1 % post -consumer Wiser

WO Fax:919-71
4
P. 02/03
rr
OPEINT ICNS
March 12, 1997
Mr, Steve W. Tedder
Water Quality Section Chief
Division of Water Quality
PO, Box 29535
Raleigh, NC 27626-0535
Re: Cl~3P Resources, lac tstonia Uiivis
Gaston County, N.C.
Gas. Division
CBP Resources, Inc.
V, x ! w. v uI LITY
t of the penalty assessed in the January 2
(the went). We would like to meet wit
it and thG Pttmut and Engineering Unit to disci the
d io elate ; position with the various dices 1,vithin the Division.
In 1995, rtegoti3rted the teams taf l ES auewai persnat with the Permit and Engineering Unit
The primary issue in those discussions was the slate's identified goal of reducing the load to Crowder
Creek Siuoe that time, we have spent considerable time and rtaotaey ill evaluating our future wastewater
tr+eatmcaat options. We now believe that the best long -team option will be to terminate our discharge to
Crowder Creek and discharge to the City of Gastonia'sPOTW. We are working toward that goal, but the
logistics of making the switch will take some time to implement.. We have been discussing this matter
with the Permit and Engineering Unit for several months and have recently proposed to them a
construction schedule to be included in our permit renewal.
It our hope that we can reach an agreement with the Permit and Engineering Unit in the near Comm
regarding the construction and compliance schedule for our new permit. In the meant me, we may
continue to have trouble complying with the terms of the current permit. We asked for an increase in the
flow volume in tour permit renewal application and aaui eipate that the volume will be increased,. We have
taken come steps to reduce our flow pending the permit renewal, tart may have occasions when we eared
the permit limit. If possible. we would like far the Division to consider a tantqxtrary flow increase pending
our permit renewal, With regard to the other cited violations, we have not exceeded our Ztttrrmonia limit in
some time, but continue to have minor exceedarices of the coliform limit. We anticipate that the
ammonia and coltforxn e`cceedanees will be under control in the very near future.
It would be very helpful tar us to nscet with representatives of the Enforcement Unit and the Permit and
Engineering Unit to discuss the status of CBPP's Permit renewal and the potential for future enforne ant
actions, and we request that such a meeting be scheduled. CBP wants to achieve full compliance as soot
as possible and behoves that our ongoing discussions with the Permit and Engineering Unit is both the
sabcs rns t© and cvideaco of our commitment to that caul. However, we are concerned that repeated and
escalating enforcement actions way be iniiiared the future anti such actions will impact our ability to
eonunit the resources necessary to work with the state in meeting its ultin me goal of r©duning the load to
Crowder Creek A meeting of all tite parties will ruse the risk that CBP will be forced to deal with two
groups within the Division that perhaps have competing goals and motivations.
5533 s. Yore Rd. • Gastonia. NC 28052 • 704-864.9941 • Fax # [phone] • Direct Dial Number,., R_

STATE OF NORTH CAROLINA
DEPART OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Water Quality
919 North Main Street Mooresville, North Carolina 28115
May 16, 1997
VAN M,. JONES
CEP RESOURCES - GASTONIA DIV.
5533 SOUTH YORK ROAD
GASTONIA NC 28052
SUBJECT: Notice of Violation - Effluent Lim:
NPDES No. NC0005011
CEP RESOURCES - GASTONIA DIV.
GASTON County
Dear VAN M. JONES:
Review of subject se
of February, 1997 reveale
parameters):
Pipe Parameter
001 50050 0/MGD
001 00310 BOD
001 31616 FEC COLT
ations
-monitoring report for the month
violation(s) of the following
Reported
Value/Unit
.3020 MGD
365.00 LBS/DA
424.0 #/100M
L.inais
Value/Type/Unit
.2570 FIN MGD
340.00 FIN LBS/DA
400.0 FIN #/100M
Remedial actions, if not already implemented, should be
taken to correct the problem(s). The Division of Water
Quality may pursue enforcement actions for this and any
additional violations of State Law. If you have questions or i
you need assistance, please call D. Rex Gleason, Regional Water
Quality Supervisor, at 704/663-1699..
Sincerely,
B. Keith Overcash
Regional Supervisor
cc: Central Files
GKB'DEX96/BL

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Water Quality
919 North Main Street Mooresville, North Carolina 281 5
April 7, 1997
VAN M. JONES
CBP RESOURCES - GASTONIA DIV.
5533 SOUTH YORK ROAD
GASTONIA NC 28052
SUBJECT: Notice of Violation - Effluent Limitations
NPDES No, NC0005011
CBP RESOURCES - GASTONIA DIV.
GASTON County
Dear VAN M. JONES:
Review of subject self -monitoring report for the month
of January, 1997 revealed violation(s) of the following
parameter(s):
Pipe Parameter
Reported Limits
Value/Unit Value/Type/Unit
001 31616 EEC COLI 898.0 #/lOOM 400.0 FIN #/lOOM
Remedial actions, if not already implemented, should be
taken to correct the problem(s). The Division of Water
Quality may pursue enforcement actions for this and any
additional violations of State Law. If you have questions or if
you need assistance, please call D. Rex Gleason, Regional Water
Quality Supervisor, at 704/663-1699.
Sincerely,
Overcash
R glonal Supervisor
cc: Central Files
GKBDEX96/BL

State of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville regional Office
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Mr. E.R. Olberding, Vice President
Carolina By -Products Resources
5533 South York Road
Gastonia, North Carolina 28052
DIVISION OF WATER QUALITY
April 3, 1997
Subject: Odor Complaint Investigations
CBP Resources WWTP
NPDES Permit No. NC0005011
Gaston County, NC
Dear Mr. Olberding:
Division of Water Quality (DWQ) and Division of Air Quality (DAQ) staff from the
Mooresville Regional Office conducted joint odor complaint investigations at the subject facility
on February 25 and 27, and March 3 and 20, 1997. This letter serves to document the findings of
the DWQ investigations relative to water quality concerns,
On February 25, 1997 John Lesley with the DWQ accompanied by Ron Slack, Barry
Adderton, and Tony McManus, DAQ, met with representatives of CBP Resources to investigate
possible sources of odors reported to the Mooresville Regional Office. Odors consistent with the
process wastewater were present in the area of the aerated lagoon. Dissolved oxygen levels in the
aerated lagoon were sufficient to prevent septic conditions. Only a trace of odors was noticeable
from the three facultative lagoons The investigation of the processing plant found a grease spill
had escaped a containment area and ran down a bank to the flood plain of Crowders Creek. A
Notice of Violation was issued for the by-pass.
A follow-up investigation was conducted on February 27, 1997 by Mr. Lesley and. DAQ
staff members, Reddy Chilumula and Ron Slack. The clean up of the grease spill discovered on
February 25 had been completed. Heavy rains on February 26 had reduced the available
freeboard in the aerated lagoon to <2 feet. Odor consistent with the process wastewater was
most noticeable near the influent end of the aerated lagoon. The Land Quality Section (LQ) was
contacted for guidance concerning dam safety requirements.
On March 3, 1997 a joint inspection of the facility was conducted with Steve Allred and
Jonathan Hartwig of LQ and Ron Slack, DAQ. The lagoon dam was inspected and found to be
satisfactory. Freeboard had been increased to approximately 2.5 feet. Odor was again
919 North Main Street.
Mooresville, North Carolina 28115
Voice 704-663-1699
FAX [phone]
An Equal opportunity/Affirmative Action Employer
50% recycled/look post -consumer paper

CBP Resources
Page 2
concentrated nearest the influent end of the aerated lagoon and was consistent with the odor
characteristic of the process wastewater,
An inspection of the wastewater treatment plant (WWTP) was conducted on March 20,
1997, Although not as noticeable, the typical process wastewater odor was present at the
influent end of the aerated lagoon Weather conditions at the time of this inspection (air
temperature was approximately 70° F and the humidity was low) allowed the odors to dissipate
more rapidly The quality of mixed liquor in the aerated lagoon continued to show improvement.
in summary, the odors associated with the facility's wastewater lagoons were consistent
with the odor of the process wastewater entering the WWTP and were not due to any apparent
operation or maintenance deficiencies, This Office recommends that CBP Resources continue to
implement wastewater reduction activities to lower the organic loading on the WWTP,
Should you have any questions regarding this report, please do not hesitate to contact Mr,
Lesley or me,
Sincerely,
D. Rex G eason, P,E,
Water Quality Regional Supervisor
cc: Central Files
Ms Mindy S, Horton

RE IN<>. i Ott t: to 0t rR Bust: 'Ess.
1997
Mr. D, Rex Gleason, PE
NC Division Of Water Quality
919 N Main Street
Mooresville, NC 281 15
Subject: NOV
CBP Resources
Gaston County, NC
Dear Rex,
Gastonia Division.
CRP Resources, Inc.
nt?PT, Of
=NT, UFA : '
kEsrai Rr~Fr,s,
1997
fikAltNf
With regard to the subject, dated February 27, 1997, the dike area where the problem
occurred will have a splash guard installed that will minimize any potential episode such
as what Mr. John Leslie observed. As soon as the necessary materials are on site, this will
be completed. In the interim, everyone will stay more cognizant of this area.
We regret this incident occurred, Should the re be y questions please let me know.
Van M Jones
Environmental
4Sa.i
5533 5, York Rd, • Gastonia, NC 28052 • 704-864-9941 • Fax # [phone] • Direct Dial Number:

State of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
DIVISION OF WATER QUALITY
February 27, 1997
C1 CEIPT REQUESTED
Mr. E.R. Olberding, Vice President
Carolina By -Products Resources
5533 South York Road
Gastonia, North Carolina 28052
Subject: Notice of Violation
NCGS 143-215.1(a)(6)
Unpermitted Discharge
CBP WWTP
NPDES Permit No. NC0005011
Gaston County, NC
Dear Mr, Olberding:
This letter documents a wastewater treatment system by-pass which was occurring at Carolina
By -Products (CBP) on February 25, 1997, Mr, John Lesley with the Mooresville Regional. Office
found that grease being loaded into a dump truck from the facility's DAF Unit had spilled over a
containment wall and was flowing downhill to the flood plain of Crowder's Creek,
The subject discharge is a violation of Part II Section D(4)(a)(1) of NPDES Permit No.
NC0005011 and NCGS 143-215.1(a)(6). It is requested that a written response be submitted to
this Office by March 15. 1997 detailing activities undertaken by CBP to ensure that future by-passes
do not occur. In responding, please address your comments to the attention of Mr, D. Rex Gleason,
Water Quality Regional Supervisor..
919 North Main Street,
Mooresville, North Carolina 28115
Voice 704-663-1699
FAX [phone]
An Equa1©pportunity/Affirmative Action Employer
50° recycled/ 10% post -consumer paper

CI3P Resources
Page 2
Should you have any questions concerning this Notice, please do not hesitate to contact
Messrs Gleason., Lesley, or me at [phone]
Sincerely,
I:3, eith Overcash,
Regional Supervisor
cc, Mike Landis, Air Quality Section,
ston County Health Department
0

AQ-16 Revised 9/19/9S G: DEM\AQ�w DATA\GO GAS
NORTH CAROLINA DIVISION OF ENVIRONMENTAL MANAGEMENT
N10017261970220,C 16
Name
CBP Resources
Contact
Type Action: CI
Air Program. Status:
Action Requested By:
Last Insp. Date 6/24/96
Permit # 3590R13
Data Tracking: 0 E
Recornrnendations:
Continue Surveillance
Air Quality Action Rerort
Location
Gastonia, Gaston County
Telephone
Other: Surveillance
Class: A
Address/Phone
Change to: _
Reg/Co./Prem.No.
03/36/00026
Reed Date
Action Date 2/20/97 Next Insp. Date Ongoing
Surveillance
Issued 9/
9/96 Expires 6/30/97
S D ITS © TOXLB q'OMPLAIN
Signature:
Tony McManus
Barry Addertion
-S'1`EPS Action Number:
Dato ?•/
-
This facility is a rendering plant that mostly processes chicken blood and feathers as raw material for dog food
manufacturers. It is located approximately one mile north of the NC/SC state line on Highway 321 (5533 South York
Road) in southern Gaston County, North Carolina.
I received a total of 24 complaints about odors from CBP for the week of February 16-21, 1997.
February 20. 1997
Barry Addertion and Tammie Watkins of MRO DAQ visited the area for odor determination. During the visit, the biofilter
was observed in operation with no odorous emissions detected,.
No odors from the facility's waste water lagoons were detected throughout the surveillance route.
Surveillance should be continued at this facility to insure compliance with the odor standard.
* Note: Odor evaluation intensity scale: 0 = no odor; 1 = very faint odor; 2 = faint odor; 3 = easily noticeable
odor; 4 = strong odor; 5 = very strong odor.
TLM:sl

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Water Quality
919 North Main Street Mooresville, North Carolina 28115
February 6, 1997
VAN M. JONES
CBP RESOURCES - GASTONIA DIV.
5533 SOUTH YORK ROAD
GASTONIA NC 28052
SUBJECT: Notice of Vic)
NPDES No. NCO
CBP RESOURCES
GASTON County
Dear VAN M. JONES:
ation - Effluent Limitations
05011
- GASTONIA DIV.
Review of subject self -monitoring report for the month
of November, 1996 revealed violations) of the following
parameter(s):
Pipe Parameter
001 31616 FEC COLI
Reported Limits
Value/Unit Value/Type/Unit
1485.0 #/100M 400.0 FIN #/100M
Remedial actions, if not already implemented, should be
taken to correct the problem(s). The Division of Water
Quality may pursue enforcement actions for this and any
additional violations of State Law. If you have questions or if
you need assistance, please call D. Rex Gleason, Regional Water
Quality Supervisor, at 704/663-1699.
Sincerely,
rh Overcash
nal Supervisor
cc: Central Files
GKBDEX96/BL

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Water Quality
919 North Main Street Mooresville, North Carolina 28115
March 3, 1997
VAN M. JONES
CBP RESOURCES - GASTONIA DIV.
5533 SOUTH YORK ROAD
GASTONIA NC 28052
SUBJECT: Notice of Violation Effluent Limitations
NPDES No. NC0005011
CBP RESOURCES - GASTONIA DIV.
GASTON County
Dear VAN M. JONES:
Review of subject self -monitoring report for the month
of December, 1996 revealed violation(s) of the following
parameter(s):
Pipe Parameter
Reported Limits
Value/Unit Value/Type/Unit
001 31616 FEC COLI 1325.0 #/100M 400.0 FIN ##/1QOM
Remedial actions, if not already implemented, should be
taken to correct the problem(s). The Division of Water
Quality may pursue enforcement actions for this and any
additional violations of State Law. If you have questions or if
you need assistance, phase call D. Rex Gleason, Regional Water
Quality Supervisor, at 704/663-1699.
Sincerely,
eith Overcash
eional Supervisor
cc: Central Files
GKBDEX96/BL

1
State of North Carolina
Department of Environment,
health and Natural Resources
Mooresville Regional Office
James B, Hunt, Jr„ Governor
Jonathan B. Howes, Secretary
DIVISION OF AIR QUALITY
March 6, 1997
Mrs, George Ratchford
5515 Sparrow Dairy Road.
Gastonia, North Carolina 28056
Subject: Odor Complaints
CBP Resources, Odors
Gastonia, North Carolina
Gaston County
03/36/00026
Air Permit No. 3590R13
Dear Mrs, Ratchford:
Reference is made to your complaint�which
le Regionaireceived
©fficethis
(fi�tRO) of the Naregard
rth Carol na
to odors
from CBP Resources,, Inc. (CBP)• The M
Division of Air Quality understands the frustration
like a ass assure you that u have experienced
rcis Office has been,and the
rendering process odors from CBP. We wouldhas
continue to monitor this situation: From 1995 to dand9the Air fiequent suQirveallance, Staff
trich total overd64t`l
complaint investigations, three compliance inspections,periodically
conducted
ed spent.t Monitoring and hours asllance well as f this nights, acility weekends, nd continue
days as the situation
conducted during normal businesst as warrants. We have also met with representatives ton andCounty
EnvironmentalDControlnin orclerl to
personnel from the South Carolina Department of Health
discuss corrective measures to be taken by CBP to alleviate the problems associated with current
facility operations.
As you are probably aware, this facility is a rendering plant that processes chicken parts, blood,
and feathers as raw material for dog food manufacturers. CBPas xperienncedfd perther iodic
cvokble
e
emission and odor problems since the October, 1995 construction/operation
and
process and associated wet scrubber control d��� the A fter trying to slaughter houses,ine-tune CBP officialalsprocess installed a
improving the quality of raw material received
ffice
biological filter designed to control odors fromthe
feather
CBP's request coordinated a
permit to
response by our Headquarters Staff in Raleigh toapprove
allow for the construction and operation Iter ishexp octedtt° reducer to trol the feather processing ors on the hodoPYbye75
According to the design engineers,
to 95 percent. A Division of Air Quality
from
Becemb©Office
16, 19961edA ditional odor control
at construction of the
bio-filter was completed and properly functioning on
stipulations were also added to the permit to assure better control of raw n for the addition of a new process that treats blood
age odors. CBP
also requested and received an air permit modification
separately from the feathers. The Company felt that the addition of this process would further reduce
odors. This process is presently in MI operation.
919 North Main Street,
Mooresville, North Carolina 28115
Voice 704-663-1699
C
FAX 704-a` a3-6040
An Ec}ual Opportunity/Affirmative Aci`rn Employer
recycled/10% past-cafsumer paper

CBP Resources
March 6, 1997
Page 2
Since October, 1995, this Office has visited CBP numet
to determine if violations of air quality regulations had occurre
CBP has been issued eight Notices of Violation (NOV) for vis
May 24, 1996 and July 30, 1996, CBP was assessed civil pen&
first four NOVs. On August 2, 1996, CBP requested to enter i.
A SOC is an agreement with a time table for corrective ac.
penalties for past infractions, as well as stipulated penalties for
The SOC was approved and went into effect on December 13
monitor CBP's compliance with the SOC time table.
The Air Quality Division of this Office feels that CBP
control devices appropriate to the rendering industry and regul
fact that CBP operates a rendering process, there will always be
the most part, any strong odors generated by the processes at t are being controlled.
Odors associated with the wastewater tereaDtmesntolagoonso appears
pPr Qual to � common
° a indicated that the lagoons
industrial activity. A recent inspection by th
were performing as required and as expected. e leratedhthe by CBPt thetCompoany srcu©entdlyrreviewing
to be a
proper way to treat the type of wastewaterg
proposals with the Division of Water Quality and the City of Gastonia to investigate alternative
wastewater treatment methods.
n of
P
The. Division of Water Quality conducted vahroutine dentlfied slep©c�podorsea d other water the qualityB
wastewater treatment system on July 31, 1996,ES
problems regarding the lagoons. An enforcement©ubm submitted Raleighf in September�t 1996 G Civildischarge
permit) violations from July, 1995 to June, 1996 was
in February, 1997
penalties of $4,450 plus investigative
costs
e and inspectiof n n onwere assessed December 3, 1996 wainst as coordinated by the
for the NPDES permit violations.
Division of Air Quality due to odor complaints. During this inspection, CBP's wastewater treatment
system appeared to be properly operating with no unusual odors detected.
w
ll cont
The North Carolina Division of Air Quality and
.Division of uality regulations. QYoulrtconclern for1t11e a©
work to insure compliance with applicable airandwaterq
quality in your area is appreciated and shared by the staff ds Office. hIfeyou
have
contact y questions Patros
with reference to this matter or if the problem reoccurs, please
Beam or John Lesley with the Division of Water Quality or Mr. Tony McManus, Ms. Tamera Eplin
or me with the Division of Air Quality at [phone].
Sincerely,
Michael S. Landis
Acting Regional Su
MSL:cf
Central Files
MR0..
W'PPATAIC©Lf1NTI ESkiAST©t` t000261 ,ATCFiFo3.CLT
for

ate of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B, Hunt, Jr„ Governor
Jonathan ,B, Howes, Secretary
DIVISION OF AIR QUALITY
March 6, 1997
Mr. John Kerpsie
5524 Old Farm Road
Gastonia, North Carolina 28056
Subject: Odor Complaints
CBP Resources, Odors
Gastonia, North Carolina.
Gaston County
03/36/00026
Air Permit No. 3590R13
Dear Mr. Kerp;
Reference is made to your complaint, which was received in this Office with regard to odors
from CBP Resources, Inc. (CBP). The Mooresville Regional Office (MRO) of the North Carolina
Division of Air Quality understands the frustration that you have experienced with regards to the
rendering process odors from CBP. We would like to assure you that this Office has been, and will
continue to monitor this situation. From 1995 to date, the Air Quality Staff has conducted 36 complaint
investigations, three compliance inspections, and frequent surveillance, which total over 600 man-hours
spent. Monitoring and surveillance of this facility will continue to be periodically conducted during
normal business hours as well as nights, weekends, and holidays as the situation warrants. We have
also met with representatives of the Gaston County Health Department as well as personnel from the
South Carolina Department of Health and Environmental Control in order to discuss corrective
measures to be taken by CBP to alleviate the problems associated with current facility operations.
As you are probably aware, this facility is a rendering plant that processes chicken parts, blood,
and feathers as raw material for dog food manufacturers. CBP has experienced periodic visible
emission and odor problems since the October, 1995 construction/operation of a feather cooking
process and associated wet scrubber control device. After trying to fine-tune this process and improving
the quality of raw material received from the slaughter houses, CBP officials installed a biological filter
designed to control odors from the feather cooker. This Office coordinated a rapid response by our
Headquarters Staff in Raleigh to approve CBP's request to modify their air permit to allow for the
construction and operation of the bio-filter to control odors on the feather process. According to the
design engineers, this filter is expected to reduce the feather processing odors by 75 to 95 percent. A
Division of Air Quality inspector from this Office verified that construction of the bio-filter was
completed and properly functioning on December 16, 1996. Additional odor control stipulations were
also added to the permit to assure better control of raw material storage odors. CBP also requested and
received an air permit modification for the addition of a new process that treats blood separately from the
feathers. The Company felt that the addition of this process would further reduce odors. This process is
presently in full operation.
919 North Mon Street, ' FAX [phone]
Mooresville, North Carolina 28115 An Equal Opportunity/A�rmative Action Employer
Voice 704-663-1699 c 50% recycled/10% post -consumer paper

!IFFIFF;BP Resources
March 6, 1997
Page 2
Since October, 1995, this Office has visited CBP numerous times to investigate complaints and to
determine if violations of air quality regulations had occurred and if so, to properly document them.
CBP has been issued eight Notices of Violation (NOV) for visible emission and odor violations. On
May 24, 1996 and July 30, 1996, CBP was assessed civil penalties totaling $15,000 in regards to the
first four NOVs. On August 2, 1996, CBP requested to enter into a Special Order by Consent (SOC).
A SOC is an agreement with a time table for corrective actions. It generally includes stipulated penalties
for past infractions, as well as stipulated penalties for failure to comply with the time table. The SOC
was approved and went into effect on December 13, 1996. This Office will continue to monitor CBP's
compliance with the SOC time table.
The Air Quality Division of this Office feels that CBP Resources has installed equipment and
control devices appropriate to the rendering industry and regulatory standards. However, due to the
fact that CBP operates a rendering process, there will always be some amount of odor emitted; but for
the most part, any strong odors generated by the processes at the plant are controllable and at present
are being controlled.
Odors associated with the wastewater treatment lagoons appears to be common to this type of
industrial activity. A recent inspection by the Division of Water Quality indicated that the lagoons
were performing as required and as expected. Although the wastewater lagoons are considered to be a
proper way to treat the type of wastewater generated by CBP, the Company is currently reviewing
proposals with the Division of Water Quality and the City of Gastonia to investigate alternative
wastewater treatment methods.
The Division of Water Quality conducted a routine annual compliance inspection of the CBP
wastewater treatment system on July 31, 1996, which identified septic odors and other water quality
problems regarding the lagoons. An enforcement recommendation for NPDES (wastewater discharge
permit) violations from July, 1995 to June, 1996 was submitted to Raleigh in September, 1996. Civil
penalties of $4,450 plus investigative costs of $284.50 were assessed against CBP in February, 1997 for
the NPDES permit violations. A second inspection on December 3, 1996 was coordinated by the
Division of Air Quality due to odor complaints. During this inspection, CBP's wastewater treatment
system appeared to be properly operating with no unusual odors detected.
The North Carolina Division of Air Quality and Division of Water Quality will continue to work
to insure compliance with applicable air and water quality regulations. Your concern for the air quality
in your area is appreciated and shared by the staff of this Office. If you have any questions with
reference to this matter or if the problem reoccurs, please do not hesitate to contact Ms. Patricia Beam
or John Lesley with the Division of Water Quality or Mr. Tony McManus, Ms, Tamera Eplin or me
with the Division of Air Quality at [phone].
Acting Regional Supervisor
MSL:cf
Central Files
TEM‘A' 6/k \GASTO 2.CLT

State of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B, Hunt, Jr,, Governor
Jonathan B. Howes, Secretary
DIVISION OF AIR QUALITY
March 6, 1997
Mr. Ken Bowers
5504 Candlewick Trail
Gastonia, North Carolina 28056
Subject: Odor Complaints
CBP Resources, Odors
Gastonia, North Carolina
Gaston County
03/36/00026
Air Permit No. 3590R13
Dear Mr. Bowers:
Reference is made to your complaint, which was received in this Office with regard to odors
from CBP Resources, Inc. (CBP). The Mooresville Regional Office (MRO) of the North Carolina
Division of Air Quality understands the frustration that you have experienced with regards to the
rendering process odors from CBP. We would like to assure you that this Office has been, and will
continue to monitor this situation. From 1995 to date, the Air Quality Staff has conducted 36 complaint
investigations, three compliance inspections, and frequent surveillance, which total over 600 man-hours
spent. Monitoring and surveillance of this facility will continue to be periodically conducted during
normal business hours as well as nights, weekends, and holidays as the situation warrants. We have
also met with representatives of the Gaston County Health Department as well as personnel from the
South Carolina Department of Health and Environmental Control in order to discuss corrective
measures to be taken by CBP to alleviate the problems associated with current facility operations.
As you are probably aware, this facility is a rendering plant that processes chicken parts, blood,
and feathers as raw material for dog food manufacturers. CBP has experienced periodic visible
emission and odor problems since the October, 1995 constniction/operation of a feather cooking
process and associated wet scrubber control device. After trying to fine-tune this process and improving
the quality of raw material received from the slaughter houses, CBP officials installed a biological filter
designed to control odors from the feather cooker: This Office coordinated a rapid response by our
Headquarters Staff in Raleigh to approve CBP's request to modify their air permit to allow for the
construction and operation of the bio-filter to control odors on the feather process. According to the
design engineers, this filter is expected to reduce the feather processing odors by 75 to 95 percent. A
Division of Air Quality inspector from this Office verified that construction of the bio-filter was
completed and properly functioning on December 16, 1996. Additional odor control stipulations were
also added to the permit to assure better control of raw material storage odors. CBP also requested and
received an air permit modification for the addition of a new process that treats blood separately from the
feathers. The Company felt that the addition of this process would further reduce odors, This process is
presently in full operation.
919 North Main Street.
Mooresville, North Carolina 28115
Voice 704-663-1699
FAX [phone]
Equal Opportunity/Affirmative Action Employer
50% recycled/10% post -consumer paper

CBP Resources
February 25, 1997
Page 2
Since October, 1995, this Office has visited CBP numerous times to investigate complaints and to
determine if violations of air quality regulations had occurred and if so, to properly document them.
CBP has been issued eight Notices of Violation (NOV) for visible emission and odor violations. On
May 24, 1996 and July 30, 1996, CBP was assessed civil penalties totaling $15,000 in regards to the
first four NOVs. On August 2, 1996, CBP requested to enter into a Special Order by Consent (SOC).
A SOC is an agreement with a time table for corrective actions. It generally includes stipulated penalties
for past infractions, as well as stipulated penalties for failure to comply with the time table. The SOC
was approved and went into effect on December 13, 1996. This Office will continue to monitor CBP's
compliance with the SOC time table.
The Air Quality Division of this Office feels that CBP Resources has installed equipment and
control devices appropriate to the rendering industry and regulatory standards. However, due to the
fact that CBP operates a rendering process, there will always be some amount of odor emitted; but for
the most part, any strong odors generated by the processes at the plant are controllable and at present
are being controlled.
Odors associated with the wastewater treatment lagoons appears to be common to this type of
industrial activity. A recent inspection by the Division of Water Quality indicated that the lagoons
were performing as required and as expected. Although the wastewater lagoons are considered to be a
proper way to treat the type of wastewater generated by CBP, the Company is currently reviewing
proposals with the Division of Water Quality and the City of Gastonia to investigate alternative
wastewater treatment methods.
The Division of Water Quality conducted a routine annual compliance inspection of the CBP
wastewater treatment system on July 31, 1996, which identified septic odors and other water quality
problems regarding the lagoons. An enforcement recommendation for NPDES (wastewater discharge
permit) violations from July, 1995 to June, 1996 was submitted to Raleigh in September, 1996. Civil
penalties of $4,450 plus investigative costs of $284.50 were assessed against CBP in February, 1997 for
the NPDES permit violations. A second inspection on December 3, 1996 was coordinated by the
Division of Air Quality due to odor complaints. During this inspection, CBP's wastewater treatment
system appeared to be properly operating with no unusual odors detected.
The North Carolina Division of Air Quality and Division of Water Quality will continue to work
to insure compliance with applicable air and water quality regulations. Your concern for the air quality
in your area is appreciated and shared by the staff of this Office. If you have any questions with
reference to this matter or if the problem reoccurs, please do not hesitate to contact Ms. Patricia Beam
or John. Lesley with the Division of Water Quality or Mr. Tony McManus, Ms. Tamera Eplin or me
with the Division of Air Quality at [phone].
MSL:cf
Sincerely`
Michael S. Landis
Acting Regional Supervisor
cc: Central Files
i1ROlf:
ATA1C OUNTIES,GAST©N1OOP26\8OW E.R S2.CLT

I
State of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
DIVISION OF AIR QUALITY
March 6, 1997
Mrs. Karen Laird
3604 Heather Lane
Gastonia, North Carolina 28056
Subject: Odor Complaints
CBP Resources, Odors
Gastonia, North Carolina
Gaston County
03/36/00026
Air Permit No. 3590R13
Dear Mrs, Laird:
Reference is made to your complaint, which was received in this Office with regard to odors
from CBP Resources, Inc. (CBP). The Mooresville Regional Office (MRO) of the North Carolina
Division of Air Quality understands the frustration that you have experienced with regards to the
rendering process odors from CBP. We would like to assure you that this Office has been, and will
continue to monitor this situation. From 1995 to date, the Air Quality Staff has conducted 36 complaint
investigations, three compliance inspections, and frequent surveillance, which total over 600 man-hours
spent. Monitoring and surveillance of this facility will continue to be periodically conducted during
normal business hours as well as nights, weekends, and holidays as the situation warrants. We have
also met with representatives of the Gaston. County Health Department as well as personnel from the
South Carolina Department of Health and Environmental Control in order to discuss corrective
measures to be taken by CBP to alleviate the problems associated with current facility operations.
As you are probably aware, this facility is a rendering plant that processes chicken parts, blood,
and feathers as raw material for dog food manufacturers. CBP has experienced periodic visible
emission and odor problems since the October, 1995 construction/operation of a feather cooking
process and associated wet scrubber control device. After trying to fine-tune this process and improving
the quality of raw material received from the slaughter houses, CBP officials installed a biological filter
designed to control odors from the feather cooker. This Office coordinated a rapid response by our
Headquarters Staff in Raleigh to approve CBP's request to modify their air permit to allow for the
construction and operation of the bio-filter to control odors on the feather process. According to the
design engineers, this filter is expected to reduce the feather processing odors by 75 to 95 percent. A.
Division of Air Quality inspector from this Office verified that construction of the bio-filter was
completed and properly functioning on December 16, 1996,.Additional odor control stipulations were
also added to the permit to assure better control of raw material storage odors. CBP also requested and
received an air permit modification for the addition of a new process that treats blood separately from the
feathers. The Company felt that the addition of this process would further reduce odors. This process is
presently in full operation.
919 North Main Street,
Mooresville, North Carolina 281 15
Voice 704-663-1699
FAX [phone]
An Equal opportunity/Affirmative Action Employer
50% recycled/ 10% post -consumer paper

CBP Resources
March 6, 1997
Page 2
Since October, 1995, this Office has visited CBP numerous times to investigate complaints and to
determine if violations of air quality regulations had occurred and if so, to proper y document them.
CBP has been issued eight Notices of Violation (NOV) for visible emission and odor violations. On
May 24, 1996 and July 30, 1996, CBP was assessed civil penalties totaling $15,000 in regards to the
first four NOVs. On August 2, 1996, CBP requested to enter into a Special Order by Consent (SOC).
A SOC is an agreement with a time table for corrective actions, It generally includes stipulated penalties
for past infractions, as well as stipulated penalties for failure to comply with the time table. The SOC
was approved and went into effect on December 13, 1996. This Office will continue to monitor CBP's
compliance with the SOC time table,
The Air Quality Division of this Office feels that CBP Resources has installed equipment and
control devices appropriate to the rendering industry and regulatory standards. However, due to the
fact that CBP operates a rendering process, there will always be some amount of odor emitted; but for
the most part, any strong odors generated by the processes at the plant are controllable and at present
are being controlled.
Odors associated with the wastewater treatment lagoons appears to be comrnon to this type of
industrial activity. A recent inspection by the Division of Water Quality indicated that the lagoons
were performing as required and as expected. Although the wastewater lagoons are considered to be a
proper way to treat the type of wastewater generated by CBP, the Company is currently reviewing
proposals with the Division of Water Quality and the City of Gastonia to investigate alternative
wastewater treatment methods.
The Division of Water Quality conducted a routine annual compliance inspection of the CBP
wastewater treatment system on July 31, 1996, which identified septic odors and other water quality
problems regarding the lagoons. An enforcement recommendation for NPDES (wastewater discharge
permit) violations from July, 1995 to June, 1996 was submitted to Raleigh in September, 1996. Civil
penalties of $4,450 plus investigative costs of $284.50 were assessed against CBP in February, 1997 for
the NPDES permit violations. A second inspection on December 3, 1996 was coordinated by the
Division of Air Quality due to odor complaints. During this inspection, CBP's wastewater treatment
system appeared to be properly operating with no unusual odors detected,
The North Carolina Division of Air Quality and Division of Water Quality will continue to work
to insure compliance with applicable air and water quality regulations. Your concern for the air quality
in your area is appreciated and shared by the staff of this Office. if you have any questions with
reference to this matter or if the problem reoccurs, please do not hesitate to contact Ms. Patricia Beam
or John Lesley with the Division of Water Quality or Mr. Tony McManus, Ms. Tamera Eplin or me
with the Division of Air Quality at [phone].
Sincerely,
, •
Michael S. Landis
Acting Regional Supervisor
MSL:cf
cc: Central Files
G:OENLAQW,TDATA \COLT4TIESZASTOM00026",,LAIRD2 CLT

pirState of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
DIVISION OF AIR QUALITY
March 6, 1997
Mr. Richard Pekarek
5525 Bud Wilson Road
Gastonia, North Carolina 28056
Subject: Odor Complaints
CBP Resources, Odors
Gastonia, North Carolina
Gaston County
03/36/0002.6
Air Permit No. 3590R 13
Dear Mr. Pekarek:
Reference is made to your complaint, which was received in this Office with regard to odors
from. CBP Resources, Inc. (CBP). The Mooresville Regional Office (MRO) of the North Carolina
Division of Air Quality understands the frustration that you have experienced with regards to the
rendering process odors from CBP. We would like to assure you that this Office has been, and will
continue to monitor this situation. From 1995 to date, the Air Quality Staff has conducted 36 complaint
investigations, three compliance inspections, and frequent surveillance, which total over 600 man-hours
spent. Monitoring and surveillance of this facility will continue to be periodically conducted during
normal business hours as well as nights, weekends, and holidays as the situation warrants. We have
also met with representatives of the Gaston County Health Department as well as personnel from the
South Carolina Department of Health and Environmental Control in order to discuss corrective
measures to be taken by CBP to alleviate the problems associated with current facility operations.
As you are probably aware, this facility is a rendering plant that processes chicken parts, blood,
and feathers as raw material for dog food manufacturers. CBP has experienced periodic visible
emission and odor problems since the October, 1995 construction/operation of a feather cooking
process and associated wet scrubber control device. After trying to fine-tune this process and improving
the quality of raw material received from the slaughter houses, CBP officials installed a biological filter
designed to control odors from the feather cooker. This Office coordinated a rapid response by our
Headquarters Staff in Raleigh to approve CBP's request to modify their air permit to allow for the
construction and operation of the bio-filter to control odors on the feather process, According to the
design engineers, this filter is expected to reduce the feather processing odors by 75 to 95 percent. A
Division of Air Quality inspector from this Office verified that construction of the bio-filter was
completed and properly functioning on December 16, 1996. Additional odor control stipulations were
also added to the permit to assure better control of raw material storage odors. CBP also requested and
received an air permit modification for the addition of a new process that treats blood separately from the
feathers. The Company felt that the addition of this process would further reduce odors. This process is
presently in full operation.
919 North Main Street,
Mooresville, North Carolina 281 15
Voice 704-663-1699
FAX [phone]
An Equal opportunity/Affirmative Action Employer
50% recycled/10% post -consumer paper

Pr CBP Resources
March 6, 1997
Page 2
Since October, 1995, this Office has visited CBP numerous times to investigate complaints and to
determine if violations of air quality regulations had occurred and if so, to properly document them.
CBP has been issued eight Notices of Violation (NOV) for visible emission and odor violations. On
May 24, 1996 and July 30, 1996, CBP was assessed civil penalties totaling $15,000 in regards to the
first four NOVs, On August 2, 1996, CBP requested to enter into a Special Order by Consent (SOC).
A SOC is an agreement with a time table for corrective actions. It generally includes stipulated penalties
for past infractions, as well as stipulated penalties for failure to comply with the time table. The SOC
was approved and went into effect on December 13, 1996, This Office will continue to monitor CBP's
compliance with the SOC time table.
The Air Quality Division of this Office feels that CBP Resources has installed equipment and
control devices appropriate to the rendering industry and regulatory standards. However, due to the
fact that CBP operates a rendering process, there will always be some amount of odor emitted; but for
the most part, any strong odors generated by the processes at the plant are controllable and at present
are being controlled.
Odors associated with the wastewater treatment lagoons appears to be common to this type of
industrial activity. A recent inspection by the Division of Water Quality indicated that the lagoons
were performing as required and as expected. Although the wastewater lagoons are considered to be a
proper way to treat the type of wastewater generated by CBP, the Company is currently reviewing
proposals with the Division of Water Quality and the City of Gastonia to investigate alternative
wastewater treatment methods.
The Division of Water Quality conducted a routine annual compliance inspection of the CBP
wastewater treatment system on July 31, 1996, which identified septic odors and other water quality
problems regarding the lagoons. An enforcement recommendation for NPDES (wastewater discharge
perrnit) violations from July, 1995 to June, 1996 was submitted to Raleigh in September, 1996, Civil
penalties of $4,450 plus investigative costs of $284.50 were assessed against CBP in February, 1997 for
the NPDES permit violations. A second inspection on December 3, 1996 was coordinated by the
Division of Air Quality due to odor complaints. During this inspection, CBP's wastewater treatment
system appeared to be properly operating with no unusual odors detected.
The North Carolina Division of Air Quality and Division of Water Quality will continue to work
to insure compliance with applicable air and water quality regulations. Your concern for the air quality
in your area is appreciated and shared by the staff of this Office. If you have any questions with
reference to this matter or if the problem reoccurs, please do not hesitate to contact Ms. Patricia Beam
or John Lesley with the Division of Water Quality or Mr. Tony McManus, Ms. Tamera Eplin or me
with the Division of Air Quality at [phone].
Sincetely,i1
S. Landis
Acting Regional Supervisor
MSL:cf
cc: Central Files
DWQ MR0
G 'DEM ). AQ WPDATA \COUNTIES ..GASTOM00026,,PEK_ARE2 CLT

ed 9/19/95 G:IDEM1AQlWPDATA\ COUNTIES IGASTQN\000261%)Id3.C16
NORTH CARGLINA DIVISION OF ENVIRONMENTAL MANAGEMENT
Name
CBP Resources
Contact
Type Action: CI X EE
Air Ptrogrnrn Status:
Action Requested By:
Last Insp. Date 6/24/96
Permit# 3590.R13
Data Tracking: 0 EMS
Recommendations:
Continue Surveillance
Quality Action Repo
Location
Gastonia, Gaston County
Telephone
Other: Surveillance
Class:
Address/Phone
Action Date 1/3/97
Issued 9/1 9/96
0 ITS
RegICo.iPrem,No.
03/36/00026
Change to: _
0 TOXLB 0 COMPLAIN
Signature:
Barry Addertion
Rec' d Date
Next Insp. Date Ongoing
Surveillance
Expires 6/30/97
-STEPS Action Number:
Date:
This facility is a rendering plant that mostly processes chicken blood and fe t ei as rave mate ial for dog food
manufacturers. It is located approximately one mile north of the NC/SC state line on Highway 321 (5533 South York
Road) in southern Gaston County, North Carolina.
January 3..1997
I was accompanied on this visit by Mr. Tony McManus. Surveillance route was conducted within 2 ih miles of the facility.
Pond odors of intensity level 2* were observed in the lower area of Salemview Road. Additional pond odors of intensity
level 1* were observed on C R Wood Road.
The purpose of the visit was to review the record keeping required by the SOC and to observe the biofilter in operation.
Mr. Gene Olberding and Mr. Van Jones were contacted to discuss these issues and to notify them that MRO had received
several odor complaints during the week. The following is a summary of the visit.
An article in The Charlotte Observer alerted DAQ personnel of a fire that occurred on December 24, 1996.
Mr. Olberding stated that a fire in the feather processor did not affect operations for more than a couple
of hours. The facility did not contact DAQ about the fire. Mr. Olberding stated that only minor damage
was sustained during the incident and that no unusual odors were detected. A visual inspection during our
visit indicated that some of the duct work had been discolored and dimpled at the elbow coming from the
feather processor.
2. Plant personnel noticed strong pond odors on. December 30, 1996. No inttnediate action was taken by the
facility.
The facility has started transporting one tanker load (approximately 5000 gallons) of high strength waste
water across Hwy 321 to Crowders Creek Waste Water Treatment facility. Mr. Jones stated the he has
noticed less odors associated with the ponds at the facility since starting this procedure. CBP is also

reviewing four proposals to improve the facility's wastewater treatment system. Mr, Olberding said that
a decision on which proposal the company will select will be made by the end of January 1997 and a first
stage operation could be in place by the summer of 1997,
4. The new blood plant will be operational by the end of January, 1997, A visual inspection indicated that
all of the blood plant hardware is in place and is being wired.
Due to safety concerns, Mr. Olberding requested that the Company not be required to wash down the yard
when the temperature is below or expected to be below freezing. Both myself and Mr. McManus agreed
and told them to discontinue the washing the yard during freezing temperatures. We also instructed Mr.
Jones to submit a letter to MRO with a formal request.
6. The biofilter was placed into operation in December 15, 1996, The SOC requires written notification
within fourteen (14) days after the deadline for completing each increment required. Written notification
was not submitted within the time allowed for the completion of the biofilter. Further review will be
necesary to determine if a violation of the SOC has occured and if a fine is warranted. Mr. Jones stated
that the letter would be mailed that day.
7. A review of the Odor Survellance log indicated a lack of details of exact locations where odors had been
detected. We instructed Mr. Jones to include more detail in the log. Mr. Jones stated that no excessive
odors associated with the feather processor has been detected on the route which would require an odor
evaluation form to be filled out.
It should be noted that the log for the raw material trailer cleanliness is kept on the Driver's Checklist Form,
Serveral days were reviewed at random and appeared to be in compliance with the SOC requirments.
The biofilter was Observed in operation with no odor emissions. The areas around the waste water ponds had odors
of intensity level 2*.
January 7. 1997
Serveral odor compliants were received at MRO during the early morning. I was in the local area and drove the
surveillance route around CBP. Pond odors of intensity level 2* were observed in the lower part of Salemview. No other
odors were noticed. 1 watched the biofilter operate for approximatily 20 minutes from Robinson Road. Due to the sun
angle, a valid visible evaluation could not be performed. Visible emissions appeared to be within the limits allowed in the
permit. A visit inside the facility was not performed.
January 8, 1997
On this morning at approximately 7:30 a,m,, Tony McManus of the MRO drove around the CBP surveillance route. Level
2* pond odors were observed along Highway 321 adjacent to CBP and also in the Salemview Subdivision. No excessive
visible emissions or process odors were detected.
Surveillance should be continued at this facility to insure compliance with the visible emissions and odor standard,
* Note: Odor evaluation intensity scale: 0 = no odor; 1 = very faint odor; 2 = faint odor; 3 = easily noticeable
odor; 4 = strong odor; 5 = very strong odor.
BWA:s1

RECNi Nu T 1 N 7 F C YC3R BUSH ss.
January 28, 1997
Mr, Keith Overcash, PE
Regional Supervisor
N C Division of Water Quality
919 N Main Street
Mooresville, NC 281 1. 5
Subject: Effluent Toxicity Testing
NPDES Permit No, NC 0005011
CBP Resources
Gaston County, NC
Dear Mr, Overcash:
Gastonia Division
CBP Resources, Inc,
This is in response to your letter of;anuary 2, 1997 regarding the subject for November,
1996.
The enclosed reportt shows a passing grade for toxicity for the month of December, 1996.
Should there be any questions, please let rrte know.
Sincerely,
Van. M Jones
Environmental Manager
ure.
5533 S, York r1. • Gastonia, NC 2S052 • 704-864-9941 • fax # 704.861 ,9252 • Direct Qua Number:_,

aborao,y Pe
ure o
Toxicity Report Form - Chronic
d Acute LC50 Date: 12"23`96
y: CBP RESOURCES NI?,DES##s NC0005011 Pipe##;. 001 County: GASTON
est:.�INGTCN RESEARCH, INC.
azure of Lahor, t© °y Supe
Work Order: 6L319-001
rob e Char
or
MAIL ORIGINAL TO:.
North Carolina Ceriodaphnia
Chronic Pass/Fail Reproduction Toxicity Test
CONTROL ORGANISMS
# Young Produced
Adult (L)ive (D)ead
29
Effluent %: 3*
TREATMENT 2 ORGANISMS 1 2
PH
# Young Produced
Adult (L)ive (D)ead
Control
Treatment 2
D.O.
Control
Treatment 2
1st sample
7.95
7.89
7.98
s
t e
a n
✓ d
1st sample
8.6
7,7
34
29
30
Convents :
Environmental Sciences Branch
Div. of Environmental Management
N.C. Dept. of EHNR
4401 Reedy Creek Road
Raleigh, North Carolina 27607-6445
4 5 6 7 8 9 10 11 12
31
23 38
31
31
L L
7
28
sample 2nd sample
7.64
7.99
7.74
7.7
$
t e
a n
r d
t.
1st sample
8.4
8.1
8.1
8.1
7.63
'7.87
7,53
7.85
t e
a n
✓ d
t
2nd sample
8.2
8.2
7.8
9
33
LCSO/Acute Toxicity Test
9ortality expressed as V, combining replicates)
29
30
39
24
Chronic Test Results
Calculated t = O.190
Tabular t = 2.508
% Reduction = 1.06
0.00
Control
Avg.Reprod.
31.50
Control
0.00
31.17
Treatment 2 Treatment 2
Control CV
1.1.039t
% control orgs
producing 3rd
brood
100t
PASS FAIL
Complete This For Either Test
Test Start Date: 12/14/96
Collection (Start) Date
Sample 1: 12/12/96 Sample 2: 12/17/96
Sample Type/Duration 2nd
1st P/F
Grab Comp. , Duratican
-
I S S
Sample 1 X 24 hrs L A A
U M M
Sample 2 X 24 hrs T P P
Hardness
Spec. Cond.( mhos)
Chlorine(mg/i)
Sample temp. at receipt(°C)
47
102
4490
<.05
2.2
4530
<.05
2.2
Concentration
Mortality
LC50 =
95 V Cont iderice Lim .ts
Method of Determination
Moving Average Probit
Spearman Karber — other
Note: Please
Complete This
Section Also
start/end start/end
pH
Organism Tested: Ceriodaphnia dubia
Duration (hrs
Contra
High
Conc.
D.Q.
Copied from D
0
AT-1 (3/87,) rev. 11/95 (
A ver. 4.32)

State of North Carolina
Department of Environment, Health and Natural Resources
Division of Water Quality
919 North Main Street Mooresville, North Carolina 28115
January 23, 1997
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Van M. Jones
CBP Resources - Gastonia Div,
5533 South York Road
Gastonia, North Carolina 28052
SUBJECT: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No. NC00()5011
CBP Resources WWTP
Gaston County
Dear Mr, Jones:.
This is to inform you that a review of your toxicity self -monitoring report form
for the month of November 1996 indicates a violation of the toxicity limitation specified
in your NPDES Permit,
You should take whatever remedial actions are necessary to eliminate the
conditions causing the effluent toxicity violations. Please be aware that North Carolina
General Statutes provide for assessment of civil penalties for violations of NPDES pennit
limitations and requirements, If it would be helpful to discuss this situation or possible
solutions, please contact M.1% John Lesley with this office at [phone].
Sincerely,
eith Overcash, P,E.
gional Supervisor
cc: Central Files
Aquatic Survey and Toxicology Unit

FACILITY NO NATION FORM
COMPLETED
TELEPHONE
DA

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Water Quality
919 North Main Street Mooresville, North Carolina 28115
December 23, 1996
VAIN M. JONES
CBP RESOURCES - GASTONIA DIV.
5533 SOUTH YORK ROAD
GASTONIA NC 28052
SUBJECT: Notice of Violation - Effluent Limitations
NPDES No. NC0005O11
CBP RESOURCES - GASTONIA DIV.
GASTON County
Dear VAN M. JONES:
Review of subject self -monitoring report for the month
of October, 1996 revealed violation(s) of the following
parameter(s):
Pipe Parameter
Reported
Value/Unit
Limits
Value/Type/Unit
001 31616 FEC COLI 442.0 #,'100M 400.0 FIN #/100M
Remedial actions, if not already implemented, should be
taken to correct the problem(s). The Division of Water
Quality may pursue enforcement actions for this and any
additional violations of State Law. If you have questions or if
you need assistance, piryse call D. Rex Gleason, Regional Water
Quality Supervisor, at 704/663-1699.
eith Overcash
Rejional Supervisor
cc: Central Files
GKBDEX96/BL

State of North Carolina
Department of Environment, Health and Natural Resources
Division of Water Quality
91'9 North Main Street Mooresville, North Carolina 28115
November 22, 1996
CERTIFIED MAIL
RETUR RECEIPT REQUESTED
Mr. Van M. Jones
CBP Resources - Gastonia Div,
5533 South York Road
Gastonia,North Carolina 28052
SUBJECT: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No. NC0005OI 1
CBP Resources WWTP
Gaston County
Dear Mr. Jones:
This is to inform you that a review of your toxicity self -monitoring report form
for the rnonth of September 1996 indicates a violation of the toxicity limitation specified
in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the
conditions causing the effluent toxicity violations. Please be aware that North Carolina
General Statutes provide for assessment of civil penalties for violations of NPDES permit
limitations and requirements. If it would be helpful to discuss this situation or possible
solutions, please contact Mr. John. Lesley with this office at [phone].
Sincerely,
eith Overcash, P.E.
Regional Supervisor
cc: Central Files
Aquatic Survey and Toxicology Unit

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Water Quality
919 North Main Street Mooresville, North Carolina 28115
November 19, 1996
VAN M. JONES
CBP RESOURCES - GASTONIA DIV.
5533 SOUTH YORK ROAD
GASTONIA NC 28052
SUBJECT: Notice of Violation - Effluent Limitations
NPDES No. NC0005O11
CBP RESOURCES _ GASTONIA DIV..
GASTON County
Dear VAN M. JONES:
Review of subject self -monitoring report for the month
of September, 1996 revealed violation(s) of the following
parameter(s):
Pipe Parameter
Reported
Value/Unit
Limits
Value/Type/Unit
001 31616 FEC COLT 1052.5 #/100M 400.0 FIN #/100M
Remedial actions, if not already implemented, should be
taken to correct the problem(s). The Division of Water
Quality may pursue enforcement actions for this and any
additional violations of State Law. If you have questions or if
you need assistance, please call D. Rex Gleason, Regional Water
Quality Supervisor, at 704/663-1699.
Sincerely,
B.m�eith Overcash
Re Tonal Supervisor
cc: Central Files
GKBDEX96/BL

State of Norh Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality.
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
October 8, 1996
Mr. Van M. Jones
CBP Resources
5533 S. York Road
Gastonia, NC 28052
Dear Mr. Jones:
OCT 17
Please refer to your letter dated August 29, 1996 requesting
exemption from certification to perform pH, D.O. and Temperature
analyses at CBP Resources. An exemption is not needed for D.O. and
temperature as they are not presently certifiable parameters.
Effective immediately, we are granting that exemption to your
facility for pH. The exemption may be withdrawn at any time there
is an applicable Rule or policy change. You are reminded that your
facility is required to use EPA approved methodology for each of
these analytical procedures. If the list of parameters performed
by the WWTP changes to include any parameters listed under l5A NCAC
2H Section .0804 other than pH, our office must be notified and
certification may be required.
If you have questions or need more additional information,
contact us at 919-733-3908. Thank you for your cooperation in this
matter.
Sincerely,
William B. Edwards, Jr.
Laboratory Section
WBE:cs
cc: Norman L. Good
Chester E. Whiting
iosial O e
Laboratory Section, 4405 Reedy Creek Road,
Raleigh, North Carolina 27607-6445
Voice 919-733-3908
FAX [phone]
An Equal Opportunity/Affirmative Action Employer
ecycies/ 10% post -consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Water Quality
919 North. Main Street Mooresville, North Carolina 28115
September 30, 1996
VAN M. JONES
CBP RESOURCES - GASTONIA DIV.
5533 SOUTH YORK ROAD
GASTONIA NC 28052
SUBJECT: Notice of Violation - Effluent Limitations
NPDES No. NC0005011
CBP RESOURCES - GASTONIA DIV.
GASTON County
Dear VAN M. JONES:
Review of subject self -monitoring report
of July, 1996 revealed violation(s) of the fo
parameter(s):
Pipe Parameter
001 00610 NH3-N
or the month
owing
Reported Limits
Value/Unit Value/Type/Unit
420.20 LBS/DA 140.00 FIN LBS/DA
Remedial actions, if not already implemented, should be
taken to correct the problem(s). The Division of Water
Quality may pursue enforcement actions for this and any
additional violations of State Law. If you have questions or if
you need assistance, p1 use call D. Rex Gleason, Regional Water
Quality Supervisor, at 704/663-1699.
Sincerely,
ith Overcash
Regional Supervisor
cc: Central Files
GK'BDEX96/BL

DIVISION OF WATER QUALITY
September 27, 1996
MEMORANDUM TO: Coleen Sullins
FROM: D. Rex Gleason
PREPARED BY:
SUBJECT:
(-)
Richard Bridgemanm-v
Nutrient Study/Alternatives Analysis
CBP Resources, Inc. - Gastonia Division
NPDES Permit No. NC0005011
Gaston County
Pursuant to the withdrawal of a Petition for Contested Case
Hearing on October 17, 1995, a renewed Permit was issued to the
subject facility on October 20, 1995, with an effective date of
November 1, 1995, and an expiration date of September 30, 1996.
The Permit modifications which allowed for the petition withdrawal
were the removal of concentration limits for Ammonia Nitrogen and,
it is assumed, a change to the date on which the subject study/
analysis had to be submitted to this Division.
The nutrient study/alternatives analysis was due on June 30,
1996. Because of Permit limits violations and the failure to
submit the subject study/analysis, on August 16, 1996 this Office
issued a Notice of Recommendation for Enforcement and Notice of
Violation to CBP Resources, Inc. Included in the company's
response (enclosed) to the Notices is a request that the Division
suspend the requirement to submit the study/analysis. An
enforcement package was forwarded to Raleigh for action on
September 3 1996.
The Permit renewal application is currently being processed
(Steve Peilei/NPDES Group and Mike Parker/MRO). It is the
recommendation of this Office that CBP Resources, Inc.. be required
to submit the subject study/analysis prior to final action on the
renewal application, unless the company will commit to connect to
the City of Gastonia/Crowders Creek WWTP by a definite date.
Please contact Richard, Mike, or me if you have any questions.
Enclosure
RMB

REc
FO
August 29, 1996.
JRBUSI.NESS.
Mr. D. Rex Gleason, P.E.
Regional Water Quality Supervisor
Division of Water Quality
919 N.Main Street
Mooresville, N.C. 28115
Dear Rex:
Gastonia. Division
CBP Resources, Inc..
This will acknowledge our August 19, 1996 receipt of the August 16, 1996 letter from B.
Keith Overcast). to E.R. Olberding with this Company. Also this will confirm my
conversation with Mike Parker on August 28, 1996 during which I advised Mike that a
response would be faxed to you on August 29, 1996 and the original availed on the same
day.
With regard to this facility's non-compliance issue and the need to evaluate our
wastewater treatment options, please see the enclosed letter from Reid. Engineering
Company addressed to you. Also, please refer to a letter I sent to Mike on August 5, 1996
commenting on the lab certification and this facility's waste water treatment plant.As these
letters indicate, we are currently evaluating the options of upgrading our wastewater
treatment plant or connecting to the City POTW. We do not believe that the nutrient
analysis discussed earlier with the state will assist in these evaluations and request that the
requirement to submit such an analysis be suspended for now.
Regarding the other matters that are addressed in your letter, our responses are set forth
below in the order they appear in your letter. Page numbers are referenced for your
convenience.
5533 S. York Rd. • Gastonia, NC 28052 • 704-864-9941 • Fax # [phone] • Darect Dial Number;

Page two
Page 3
1) The water level in 1 lagoon has been lowered approximately 1.5 feet to allow
adequate freeboard.
2) The clarifier performance has improved. Mixed liquor solids are settling better and
polymer is not being added at this time.
3) We will begin to periodically check the chlorine contact chamber for solids
accumulation.
Page 4
1) The flow recorder is now in operation utilizing strip charts.
2) Original certified lab reports are already meeting this criteria.
3) Bench notes and data logs are already in use.
4) Process control data is already being maintained.
5) In the future calibration of the flow meter will be properly documented and will be
performed monthly.
Page 5
1) Please refer to my letter of August 5, 1996 to Mike Parker regarding our use of an
outside certified lab. However, we do wish to continue performing the analyses for pH,
D.Q. and temperature. Since this facility is not currently certified to perform these
analyses, please accept this as a formal request for the exemption noted in your letter for
three or less parameters. On August 1, 1996 we began daily calibration and documentation
of our pH and D.U. meters.We have also have purchased a NIST thermometer for
standardizing temperature measurements.
2) We have begun using ice rather than an ice block during composite sampling. We will
also measure temperature and document as prescribed.
3) Presently flow fluctuates less than the 15% allowable and samples are collected on a
constant flow/ constant time method.As soon as we can illustrate this with flow charts we
will request permission from you to continue this sampling mode.
Page 6
1.) BUD samples are sent to a certified lab for NPD.ES reporting.

Should e be any' que o pleac ids
Vanhones
En r munental Manager

Reid 2 rig ec r r1iti
Reid'Engineering Coinpaiiy1 Inc.
Consulting Ft-win:millet-tit) Engineers
Specializing in the Design and Operation of Viii'cifer Poilitishon Control Systems
August 27, 1996
Mr. Rex Gleason, P.E.
Regional Supervisor
North Carolina Department of Environment,
Health and Natural Resources
Division of Environmental Management
Water Quality Section
P. O. Box 29535
Raleigh, North Carolina 27626-0535
SUBJECT: CBP RESOURCES, GASTONIA, NORTH CAROLINA
WASTEWATER TREATMENT SYSTEM UPGRADE
Dear Mr. Gleason:
CBP Resources in Gastonia, North Carolina has retained Reid Engineering
Company to develop a concept design and Implementation Schedule for
upgrading and expanding the existing CBP Resources wastewater treatment
system in Gastonia, North Carolina. This upgrade plan and schedule will be
completed in the following phases:
Phase I:
Design and install an upgrade to the existing wastewater treatment
system to maintain compliance with the existing NPDES permit
limitations at the present rendering plant maximum daily
production capacity of 9,000,000# of raw material/week.
Phase II: Design and install an expansion to the upgraded wastewater
treatment system to accommodate an expansion in rendering plant
production capacity to 15,000,000# raw material/week while
maintaining compliance with existing NPDES permit limitations.
210 Princess Anne Street • Frederick,. durgi Virginia 22401 * 540-371-8500 540-371-8576
e1,3,BN,roi ALII.Miniit, cieurgut, Mahe, 1U.inws,• Iowa. Maine, Maryiiiiridi
Mississippi, Missouri, NebrAska„ New Pisoy, Nev,' York, NoTfli CArohna, ()trio, Okkihoina, Fonnsylwmia„ Too$, VirginW. Waskirigtom. West Vitgina.

Mr. Rex Gleason, P.E.
North Carolina Department of Environment
Health and Natural Resources
August 27, 1996
Page 2
Phase Ill: Design and install an upgrade to the expanded wastewater
treatment system to provide nutrient removal capability to comply
with proposed new NPDES permit limitations of 1 mg/L Total
Phosphorous and 4 mg/L Total Nitrogen.
Reid Engineering Company has been authorized to proceed with Phase I
engineering services by CBP Resources as required to upgrade the existing
wastewater treatment system to comply with existing NPDES permit
limitations. The following alternatives are presently being evaluated by Reid
Engineering Company to determine a concept design for the Phase I upgrade
to improve existing wastewater treatment system performance:
1. The installation of a new wastewater pretreatment system will be
necessary to reduce the pollutant concentrations contained in the
washdown and drainage wastewater discharged from the rendering plant
into the existing Activated Sludge Aeration Lagoon #1. These proposed
wastewater pretreatment system improvements include the installation
and operation of a new first stage Gravity Skimmer Basin for removal of
free grease and settleable solids and a new second stage Dissolved Air
Flotation Cell to provide BOD, TSS and. TKN removal by chemical
coagulation, flocculation and flotation.
The installation of a new Anaerobic Basin is being considered to provide
third stage wastewater pretreatment and 7 day hydraulic flow
equalization of blended raw condensate wastewater and pretreated
washdown drainage wastewater upstream of existing Activated Sludge
Aeration Lagoon #1. This anaerobic basin would be operated to
provide additional pretreatment of BOD and more uniform 7 day, 24
hour pollutant loading and hydraulic loading on the downstream existing
Activated Sludge Aeration. Lagoon #1.
The feasibility of converting existing Activated Sludge Aeration Lagoon
#1 into a new Anoxic Lagoon designed to provide combined wastewater

Mr. Rex Gleason, P.E.
North Carolina Department of Environment
Health and Natural Resources
August 27, 1996
Page 3
pretreatment and 7 day hydraulic flow equalization upstream from a new
Activated Sludge Aeration Basin will also be evaluated. Existing Lagoon
#1 can be converted into an anoxic lagoon providing combined
carbonaceous BOD removal, 7 day hydraulic flow equalization and
denitrification of nitrate contained in treated wastewater recycled from
the final clarifier discharge back to Lagoon #1.
4. The feasibil.ty of installing a new second stage Activated Sludge
Nitrification Basin designed to provide year around high efficiency
ammonia nitrogen removal is being evaluated. This new Activated
Sludge Aeration Basin would also be designed to provide partial nitrate
removal by biological denitrification.
5. Installation of modifications or additions to the existing final clarification
system will be evaluated to provide increased final clarification capacity
for activated sludge solids contained in the mixed liquor discharged from
existing Activated Sludge Aeration Lagoon #1.
Reid Engineering Company proposes to complete an evaluation of Phase
I wastewater treatment system upgrade alternatives and present concept design
recommendations to CBP Resources by the end of September 1996. A Phase
I Project Implementation Schedule will be determined at that time after
acceptance of a final concept design by CBP Resources. A Phase I treatment
system upgrade Concept Design and Implementation Schedule will then be
submitted to the State of North Carolina Department of Environment, Health
and Natural Resources (DEHNR) in October 1996.
Phase II engineering services to be completed by Reid Engineering
Company will include the evaluation of nutrient removal processes such as
physical/chemical removal of phosphorous, biological phosphorous removal and
nitrogen removal by nitrification/denitrification. The feasibility of installing
these nutrient removal processes in the Phase II treatment system
upgrade/expansion will be evaluated to determine the potential capital and

Mr. Rex Gleason, P.E.
North Carolina Department of Environment
Health and Natural Resources
August 27, 1996
Page 4
operating cost savings to be obtained by CBP Resources by incorporation of
nutrient removal processes in the Phase II treatment system upgrade/expansion
project.
During the completion of the conceptual design evaluation in both Phase
I and Phase II, the alternatives of complete treatment with continued discharge
to a receiving stream, or, pretreatment with discharge to the City sewer system
will be compared to determine which discharge alternative is the most feasible
and secure for long term planning purposes for CBP Resources.
The assistance of the DEHNR on this CBP Resources wastewater
treatment system upgrade project is greatly appreciated.
Sincerely,
REID ENGINEERING COMPA1VY, INC
John 11. Reid, P.E.
President
JHR/ca

TEL :
Aug 29'96 16:1 No.017 P.01
Facsimile Cover Sheet
DATE:
To: '
Company: /.
Re: , .
From:
Company: CBP R=S1JR S
GASTONIA DIVISION
5533 S. York Road
Gastonia, NC
P one: (704) 864-G941
Fax; [phone]
Pages including this
cover page: __I
Comments:

TEE
Aug
29'96 16:13 Na .01 P.02
August 29, 1996
P.E.
919N.
Mooresville, N.C. 28115
Dear Rex:
Gastonia Division
CBP Resources, Inc.
uur August 19, 1996 me* 16, 1996 letter from B
C}� with this Company. confirm my
conversation with Mike Parker on August 28, 1996 during why I advised Mike that a
r�onse would be iced to you uu August 29, 1996 and the original mafiei on the sante
With regard to this facility's ncifr-campfutnce issue and the need to evaluate uur
c rastewater treatment options, please see the enclosed letter from Reid Engineering
Company addressed to you Also, please refer r to a letter I sent to Mike on August 5, 1996
conmenting on the lab certification and this ftmlity's waste water treatment plantAs these
letters indicate, we are =may evaluating the options of upgrading our wastewater
treatment plant or connecting to the City POTW. We do not believe that the o neat
request that the
analysis discussed earlier with the
submit Such .m
Regarding the other matters that are
below in the order they appear in your
convenience,
these
far now.
letter, our responses are set forth
are weed for your
5533 5. yak RC. • Caston a. NC 28052 • 704-8641941 • Fax # [phone] • •

TEL:
Aug 29'96 1 :1.4 Na .01T P .03
Page two
Page
1) The owr Ord
2)
3)Beach n
4) Process control
5) in the future calibration
performed monthly.
in operation utilizing charts.
are already meeting tins feria.
already in use.
bed maintained.
e flaw meter will be proper dated and
Page 5
i) Please rear to my lac of August
outside certified lab. However, we do wish to
D O. and temperature, Since thus is not
ect
analys, Plcasc av apt tfiys fang _.: t...
,., ar.a.T re:gtt.
vilest; parameters. Ou August 1, 1996 we
our pH and D.O. meters.We have also have purchased a MST
etandardiabig temperature
2) We have begun using ice rather than am ice black dnrmg compa
also measure temperature and document as phi.
3) Presently flow fluctuates less than the 15% allowable and samples are collected on. a
constant flow/ constant time mathod..AR soon as we eau illustrate this with flow charts we
will request permission from you to true this sampling mode,
Page 6
1) BOD samples are seat to a cued lab for NPfES repotting

TEL: Rug 29
616:4 No 0 7 P 04;

TEL:
Aug 29'96 16:15 No .017 P.05
Reid Engineering Company Inc.
Consulting Environmental F,rigirttera.
Sr...rializirts frtha Ctataign and Op4retion of Water Pollution Control Syatarna
August 27, 1996
Mr. Rex Gleason, P.E..
Regional Supervisor
North Carolina Department of Environment,
Health and Natural Resources
Division of Environmental Management
Water Quality Section
P. O. Box 29535
Raleigh, North Carolina 27626-0535
SUBJECT: CBP RESOURCES, GASTONIA. NORTh CAROLINA
wASTEWATER TREATMENT SYSTEM UPGRADE
Dear Mr. Gleason:
CB? Resources in Gastonia, North Carolina has retained Reid Engineering
Cornpany to develop a concept design and Implementation Schedule for
upgrading and expanding the existing CRP Resources wastewater treatment
system in Gastonia, North Carolina. This upgrade plan and schedule ill be
completed in the following phases:
Phase I;
Design and install an upgrade to the existing wastewater treatment
system to maintain compliance with the existing NPDES permit
limitations at the present rendering plant maximum daily
production capacity of 9,000,000# of raw material/week.
Phase II: Design and install an expansion to the upgraded wastewater
treatment system to accommodate an expansion in rendering plant
production capacity to 15,000,000# raw material/week while
maintaining compliance with existing NPDES permit limitations.
12i0 Princess Anne Street • Predericksburg.Virginia 22401 *
FAX , 76
fllm'i. kwr, h,
uth .T T Wa%rdriallr, West Virginia

TEL:
Aug 29'96 16.1 Na.a17 P.06
Mr. Rex Gleason, P.E.
North Carolina Department at Enw r
Health and Natural Resources
August 27, 1996
Page 2
Phase LIE: Design and install an upgrade to the expanded wastewater
treatment system to provide nutrient removal capability to damply
with proposed new NPDES permit limitations of 1 nng[L Total
Phosphorous and 4 rnglL Total Nitrogen.
Reid Engineering Company has been authorized to proceed with Phase, I
engineering services by CBP Resources as required to upgrade the existing
wastewater treatment system to comply with existing NPDES permit
limitations. The following alternatives are presently being evaluated by Reid
Engineering Company to dctermine a concept design for the Phase I upgrade
to improve existing wastewater treatment system performance;
1. The installation of a new wastewater pretreatment system will be
necessary to reduce the pollutant concentrations contained in the
washdown and drainage wastewater discharged from the rendering plant
into the existing Activated Sludge Aeration. Lagoon #f. These proposed
wastewater pretreatment system improvements include the installation
and operation of a new first stage Gravity Skimmer Basin for removal of
free grease and settleable solids and a new second stage Dissolved Air
Flotation Cell to provide BOD, TSS and TKN removal by chemical
coagulation, flocculation and flotation.
The installation of a new Anaerobic Basin is being considered to provide
third stage wastewater pretreatment and 7 day hydraulic flow
equalization of blended raw condensate wastewater and pretreated
washdown drainage wastewater upstream of existing Activated Sludge
Aeration Lagoon #1. This anaerobic basin would be operated to
provide additional pretreatment of BOD and more uniform 7 day, 24
hour pollutant loading and hydraulic loading on the downstream existing
Activated Sludge Aeration Lagoon #1
The feasibility of converting existing Activated Sludge Aeration Leo©n
#1 into a new Anoxic Lagoon designed to provide combined wastewater

TEL: Rug 29'96 16:16 No.017 P.07
Mr. Rex Gleason, P.E.
North Carolina Department of E
Health and Natural Resources
August 27. 1996
Page 3
ent
pretreatment and 7 day hydraulic flow equalization upstream from, a new
Activated Sludge Aeration Basin will also be evaluated. Existing Lagoon
#1 can be converted into an anoxic lagoon providing combined
carbonaceous BOD removal., 7 day hydraulic flow equalization and
denitrification of nitrate contained in treated wastewater recycled from
the final clarifier discharge back to Lagoon #1.
The feasibility of installing a new second stage Activated Sludge
Nitrification Basin designed to provide year around high efficiency
ammonia nitrogen removal is being evaluated. This new Activated
Sludge Aeration Basin would also be designed to provide partial nitrate
removal by biological denitrification.
Installation of modifications or additions to the existing final clarification
system will be evaluated to provide increased final clarification capacity
for activated sludge solids contained in the mixed liquor discharged from
existing Activated Sludge Aeration Lagoon #L
Reid Engineering Company proposes to complete an evaluation of Phase
I wastewater treatment system upgrade alternatives and present concept design
recommendations to CBP Resourres by the end of September 1996. A Phase
1 Project Implementation Schedule will be determined at that time after
acceptance of a final concept design by CBP Resources. A Phase I treatment
system upgrade Concept Design and Implementation Schedule will then be
submitted to the State of North Carolina Department of Environment, Health
and. Natural Resources (DEB.NR) in (October 1996.
Phase 11 engineering services to be completed by Reid Engineering
Company will include the evaluation of nutrient removal processes such as
physical/chemical removal of phosphorous, biological phosphorous removal and
nitrogen removal by nitrification/denitrification.. The feasibility of installing
these nutrient removal processes in, the Phase II trcatmcnt system
upgradefeApansion will be evaluated to determine the potential capital and

TEL: Aug 29'96 16:16 No.017 P.08
Mr. Rex Gleason, P.E.
North Carina Department of Environment
Health and Natural Resources
August 27, 1996
Page 4
operating cost savings to be obtained by CBP , es y incorporation of
nutrient removal processes in the Phase II treatment system upgrade "expansion
project.
During the completion of the conceptual design evaluation in both Phase
I and Phase II, the alternatives of complete went with continued discharge
to a receiving stream, or, pretreatment with discharge to the City sewer system
will be compared to determine which discharge alternative is the most feasible
and secure for long term planning purposes for GBP Resources.
The assistance of the DEHNR on this GBP Resources wastewater
treatment system upgrade project is greatly appreciated.
Sincerely
GI i ING COMP " Y INC.
Reid, P.E.
President

RECYCLINI ;. T E Y t E of OUR NE,SS.
Septeber 24, 1996.
Mr. Rex Gleason, P.E.
Regional Water Quality Supervisor
N.C. Division of Water Quality
919 N. Main Street
Mooresville, N. C. 28115
Subject: August - 1996 Self Monitoring Report
CBP Resources
Gaston. County, N. C.
Dear Rex:
Gastonia Division
CBP Resources, inc.
Enclosed is a copy of the subject report. As requested by your Office, we are using a
certified laboratory for our NPDES testing. The results show this facility in compliance
for August, 1996.even though there were some wide ranges in the data.
Should there be any questions, please let me know.
Sincerely,
x
1
Van M. Jones
Environmental Manager
Enclosure
5533 5, York Rd. • Gastonia, NC 28052 • 704-864-9941 • Fax # [phone] • Direct Dial Number:

EFFLUENT
NPDES PERMIT NO..
FACILITY NAME
OPERATOR IN RESPONSIBLE CHARGE (ORC
CERTIFIED LABORATORIES (1)
CHECK BOX IF ORC HAS CHANGED
Mail ORIGINAL and ONE COPY ID:
ATTN; CENTRAL FILES
DI'V.OF ENVIRONMENTAL MANAGEMENT
DEHNR
P,O„ BOX 29535
R LEIGH, NC 6
Enter Parameter Code
Above Name and Units
Below
DISCHARGE NO, 0 ( f. MONTH ,r7_
CLASS COUNT'
,x GRADE , L'- PHO
(2) C.: ,,"; r
PERSO ai;S)1 CQLLEFC'I"1NG SA\1PLES
NATURE OF OPERATOR IN RESPONSIBLE CI'IARGE
BY THIS SIGNATURE, i CERTIFY THAT THIS REPORT IS
ACCURATE AND COMPLETE TO THE BEST OF MY ENOWLEDG
YEAR
DEM Form MR- I,
(Rcvised 12/941

Facility Status: (Please check one of the followin
All monitoring data and sampling frequencies meet permit requirements
All monitoring data and sarnpiing frequencies do NOT meet permit. requirements
Compliant
Noncompliant
If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, maintenance, etc.,
and a time table for improvements to be made.
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance
with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the inforrnation, the
information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations."
2,6;4
Pe tee Meuse print or type),,
.„." ,
Penni:nee Address
( 7
Signature of Perrnittee*
C/ 6 9 ',;"
Phone Number
Date
00010 Temperature
00076 Turbidity
00080 Color (Pt -Co)
00082 Color (ADM')
00556
00600
00610
00625
00095 Conductivity 00630
00300 Dissolved Oxygen
00310 BOD5 00665
00340 COD 00720
00400 pH 00745
00530 Total Suspended 00927
Residue 00929
00545 Settleable Matter 00940
PARAMETER CODES
Oil 8c Grease 00951 Total Fluoride
Total Nitrogen 01002 Total Arsenic
Ammonia Nitrogen
Total Kjeldhal 01027 Cadmium
Nitrogen
Nitrates/Nitrites 01032 Hexavalent Chromium
01034 Chromium
Total Phosphorous
Cyanide 01037 Total Cobalt
Total Sulfide 01042 Copper
Total Magnesium
Total Sodium 01045 lion
Total Chloride 01051 Lead
01067
01077
01092
01105
Nickel
S ilver
Zinc
Aluminum
50060 Total
Residual
Chlorine
01147 Total Selenium 71880 Formaldehyde
31616 Fecal Coliforrn 71900 Mercury
32730 Total Phenolics 81551 Xylene
34235 Benzene
34481 Toluene
38260 MBAS
39516 PCBs
50050 Flow
Parameter Code assistance may obtained by calling the Water Quality Compliance Group at [phone], extension 581 or 534.
The monthly average for fecal coliform is to be reported as a GEOMETRIC mean. Use only units designated in the reporting
facility's permit for reporting data.
* ORC must visit facility and document visitation of facility as required per 15A NCAC 8A .0202 (b) (5) (B).
** If signed by other than the permittee, delegation of signatory authority must be on file with the state per 15A NCAC 2B M506 (b)
(2) (D).

EFFLUENT
NPDES PERMIT NO. (;,, 0 (;)(,) 7C.11 DISCHARGE NO, CO MONTH /, YEAR
FACILITY NAME Cij/4) itz_.,7;c:.; cz„ CLASS JL cpuliV
OPERATOR IN RESPONSIBLE CFIARGF (ORC).//fif! VC, /4 s GRADE f),_L- PHONE
CERTIFIED LABORATORIES (1) (2) Cfs:
CHECK BOX IF ORC HAS CHANGED PERSON(S) COLLECTING SAMPLES i
Mail ORIGINAL and ONE COPY to:
ATTN:. CENTRAL FILES
DIV. OF ENVIRONMENTAL, MANAGEMENT
DEHNR
P.O. BOX 29535
RALEIGH, NC 2762
HRS
2!
4
6
FLOW Enter Parameter Code
Above Name and Units
'to EFF Below
INF 0
tig
ERAGE
M.AXEMUNL
MINIMUM
Coup. (C) Grab (G)
Monthly Limit
I NATURE OF OPERATOR IN RESPONSIBLE CHARGE)
BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS
ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE,
DATE
DEM Form MR-1.1
(Revis4d 12/9,1)

NPDES No �':t : a I°3SCIIAI E NO. MONTH
FACILITY NAME Ct r �� * `" <.' COL. TY
STREAM i.:,° #°°'". STREAM
LOCATION
LOCATION ,
Upstream
Do
ns
Enter Parameter Code
Above Name and
Units Below
tter Parameter Coda
Above Name and
Unity Below

DIVISION OF WATER QUALITY
September 17, 1996
MEMORANDUM TO: William B. Edwards
State Laboratory
FROM: Rex GleasonP
PREPARED BY: Richard Bridgeman
SUBJECT:
Laboratory Certification Exemption
CBP Resources
NPDES Permit No. NC000501.1
Gaston County
Enclosed is a copy of a letter from the subject facility,
which was sent to this Office in response to a Compliance Sampling
Inspection Report. Included in the enclosed letter is a request
for an exemption from obtaining laboratory certification for
parameters for which analyses/measurements are typically made on -
site.
Please advise this Office if you would prefer such requests to
be handled in another manner.
Enclosure
RMB

Gastonia Division
CBP Resources, Inc.
August 29, 1996
Mr. D. Rex Gleason, P.E.
Regional Water Quality Supervisor
Division of Water Quality
919 N.Main Street
Mooresville, N.C. 28115
Dear Rex:
This will acknowledge our August 19, 1996 receipt of the August 16, 1996 letter from B.
Keith Overcash to E.R Olberding with this Company. Also this will confirm my
conversation with. Mike Parker on. August 28, 1996 during which 1 advised Mike that a
response would be faxed to you on August 29, 1996 and the original mailed on the same
day.
With regard to this facility's non-compliance issue and the need to evaluate our
wastewater treatment options, please see the enclosed letter from Reid Engineering
Company addressed to you. Also, please refer to a letter i sent to Mike on August 5, 1996
commenting on the lab certification and this facility's waste water treatment plant.As these
letters indicate, we are currently evaluating the options of upgrading our wastewater
treatment plant or connecting to the City POTW. We do not believe that the nutrient
analysis discussed earlier with the state will assist in these evaluations and request that the
requirement to submit such an analysis be suspended for now.
Regarding the other matters that are addressed in your letter, our responses are set forth
below in the order they appear in your letter. Page numbers are referenced for your
convenience.
5533 S. York Rd. • Gastonia, NC 28052 • 704-864 941 • Fax # [phone] • Direct Dial Number

Page two
Page 3
1) The water level in # 1 fagtw o
adequate freeboard.
2) The clarifier performance has improved. Mixed
polymer is not being added at this time.
3) We will begin to periodically check the chlorin
accumulation
has been lowered approximately 1.5 feet to allow
liquor solids are settling better and
contact chamber for solids
Page 4
1) The flow recorder is now in operation utilizing strip charts.
2) Original certified lab reports are already meeting this criteria.
3) Bench notes and data logs are already in use.
4) Process control data is already being .maintained.
5) In the future calibration of the flow meter will be properly documented and will be
performed monthly.
Page 5
1) Please refer to my letter of August 5, 1996 to Mike Parker regarding our use of an
outside certified lab, However, we do wish to continue performing the analyses for pH.
D.O. and temperature. Since this facility is not currently certified to perform these
analyses, please accept this as a formal request for the exemption noted in your letter for
three or less parameters. On August 1, 1996 we began daily calibration and documentation
of our pH and D.O. rneters.We have also have purchased a NlST thermometer for
standardizing temperature measurements.
2) We have begun using ice rather than an ice block during composite sampling. We will
also measure temperature and document as prescribed. are collected on a
3) Presently flow fluctuates less than the 15% allowable and samples
constant flow' constant time rnethod.As soon as we can illustrate this with flow charts we
will request permission from you to continue this sampling mode.
Page 6
11 BOD samples a
ent to a certed lab for NPDES reporting.

Sho d ere be any nue'cn p et

pirr
State of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr„ Governor
Jonathan B, Howes, Secretary
DIVIS
August
Mr. E.R. Olberding, Vice President
Carolina By -Products Resources
5533 South York Road
Gastonia, North Carolina 28052
Subject.:
Dear Mr. Olberding:
ON OF WATER. QUALITY
26, 1996
Results from Effluent
Sampling Analyses
Carolina By -Products WWTP
NPDES Permit No. NC0005011
Gaston County, NC
Enclosed please find the results from the laboratory analyses
performed on the effluent samples from the Carolina By -Products
wastewater treatment facility. The samples analyzed were composite
and grab samples from the Compliance Sampling Inspection performed
by Patricia Beam of this office on July 31, 1996.
The results show noncompliance with the permit effluent limit
for Biochemical Oxygen Demand (BOD) at the time of sampling. The
permitted daily maximum concentration limit for BOD is 317 mg/1.
The BOD effluent value for the Carolina By -Products facility was
320 mg/l, The facility is compliant with all other permit
limitations. Carolina By -Products must make all efforts necessary
to ensure effective wastewater treatment and Permit compliance.
Please attach this letter to the inspection report dated
August 16, 1996 to complete your records on the inspection. A copy
of this letter and the results should be forwarded to the Operator
in Responsible Charge for the subject facility. If you have any
further questions regarding this matter, please do not hesitate to
contact Ms. Beam or me at [phone].
Sincerely,
D. Rex G
Water Qua
Enclosure
PS
919 North Main Street,
Mooresvi Ie, North Carolina 28115
Voice 704-663-1699
ason, P. E.
ity Regional Supervisor
FAX [phone]
An Equal Opportunity/Affirmative Action Employer
50% recyceed/ 10% post -consumer paper

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! E REGIONAL DI FILE

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Water Quality
919 North Main Street Mooresville, North Carolina 28115
September 3, 1996
VAN M. JONES
CBP RESOURCES - GASTONIA DIV.
5533 SOUTH YORK ROAD
GASTONIA NC 28052
SUBJECT: Notice of Violation - Effluent Limitations
NPDES No. NC0005011
CBP RESOURCES - GASTONIA DIV.
GASTON County
Dear VAN M. JONES:
Review of subject self -monitoring report for the month
of June, 1996 revealed violation(s) of the following
parameter(s):
Pipe Parameter
Reported Limits
Value/Unit Value/Type/Unit
001 00610 NH3-N 460.00 LBS/DA 140.00 FIN LBS/DA
Remedial actions, if not already implemented, should be
taken to correct the problem(s). The Division of Water
Quality may pursue enforcement actions for this and any
additional violations of State Law. If you have questions or if
you need assistance, plo-Ise call D. Rex Gleason, Regional Water
Quality Supervisor, at 704/663-1699.
Sincerely,
B. eith Overcash
R onal Supervisor
cc: Central Files
GKBDEX96/BL

July 25, 1996
MEMO
To: Rex Gleason
Through: Keith Overcas
From: Chet Whiting(
Subject: Compliance Monitoring Analysis by CBP Resources, Gastonia
Per State Regulation NCAC 2H .0800 all Class 1, & II Wastewater
Treatment Laboratories were required to submit an application to
this office by July 1, 1995, or within ninety days of a request by
the State Laboratory. Such a request was made to CBP Resources in
a letter dated January 30, 1995.
Certification parameter checklists were mailed to CPB Resources in
May of 1995. These were completed and returned by CBP in July of
1995.
Certification performance ampules and additional parameter
checklists were delivered to CP'B Resources by the inspector in
November of 1995.
After repeated attempts an initial inspection was scheduled, and
conducted on February 7, 1996. The inspection report was sent to
CBP from Raleigh on February 22, 1996 by certified mail. The
response was due within thirty days.
In addition, on February 9, 1996 reference materials that would
assist CBP in meeting certification requirements were sent from
this office.
Correspondence was received from CEP Resources in this office on
March 20, 1996 requesting additional time to correct deviations
cited in the inspection report. An extension for the requested
time was granted. The letter specified a response by May 22, 1996.
On June 5, 1996 a letter was sent from this office requiring CBP
Resources to send compliance monitoring samples to a certified
laboratory effective July 1, 1996.
In a subsequent telephone conversation Mr. Van Jones indicated that
some parameters would be analyzed by a certified laboratory. Other
parameters would continue to be analyzed by CBP Resources.. Mr.
Jones stated that contracting all analyses to a certified
laboratory would create a monetary hardship, as would the "
extensive" corrections required by the laboratory audit. At this
time he., was directed to contact Mr. William B. Edwards, Jr.

Pg2 MEMO
Mr. Jones contacted Mr. James Meyer of this ©f .±ce by telephone,
and was again referred to Mr. William. Edwards.
To this date we have received no correspondence indicating the
deviations cited in the laboratory audit have been addressed.
Further, the required performance ampule evaluation results have
not been received by this office.
It is apparent that CBP Resources has had ample time to
certification requirements, or make arrangements with certi
laboratories to conduct analysis of compliance monitoring samp
eet
ied
es.
Until the above problems are addressed this laboratory can not be
granted certification. The nature and number of corrections
required to meet regulatory and method requirements are of great
concern. Since the compliance monitoring analyses at CPB are not
conducted according to specifications in 15A NCAC2H,.0800 we
recommend that data not analyzed be a certified laboratory be
rejected.
Once the deviations cited in the initial report have been
corrected, this office will conduct a follow-up audit to assess
laboratory capability for the analysis of compliance monitoring
samples.
cc: William B. Edwards, Jr.
Norm Good,
Tony McManus

Gastonia Division
CBP Resources, Inc.
11E0'0,1 NG. THE NAll RE of
August 5, 1996
BUSINESS.
Mr, Mike Parker
N.C. Division of Water
919 N. Main Street
Mooresville, N. C. 28115
Dear Mr, Parker:
This will confirm our conservation on August 1, 1996,
The first item we discussed regarded the status of the lab certification for this facility.1 advised that until
we could get all the details resolved we will utilize a commercial laboratory for BOD,TSS,NH3 as N,Total
Nitrogen,Total Phosphorus,C3i1 & Grease,and fecal coliforni.Field parameters will be conducted by
company personell.
Secondly, is the subject of our wastewater plant.This facility has had preliminary discussions with the
City of Gastonia about discharging industrial wastewater to the City's Crowders Creek wastewater
treatment plant. We are also evaluating various options to up -grade the exiting on -site treatment system
to meet not only its NPDES permit conditions but also future growth of the business,
The Company has put in a significant amount of time and resources in projecting the future growth of the
poultry industry and the ability of this Company to accornodate this growth with respect to both
production and the treatment of the resulting wastewater.
The Company apologizes for any inconvenience we may have caused.
\an M. Jones
Environmental Manager
5533 5, York Rd. Gastonia, NC 8052 • 704-864 9941 • Fax # [phone] • Direct Dial Number;

State of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B, Hunt, Jr., Governor
Jonathan B. Howes, Secretary
DIVISION OF WATER QUALITY
August 16, 1996
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. E.R. Olberding, Vice President
Carolina By -Products Resources
5533 South York Road
Gastonia, North Carolina 28052
Subject: Notice of Recommendation for
Enforcement and Notice of
Violation
Compliance Sampling
Inspection
Carolina By -Products WWTP
NPDES Permit No. NC0005O11
Gaston County, NC
Dear Mr. Olberding:
Enclosed is a copy of the Compliance Sampling Inspection
Report for the inspection conducted at the subject facility on July
31, 1996, by Ms. Patricia Beam of this office. Results from the
effluent sampling analysis will be forwarded under separate cover
when available.
This report is being issued as a Notice of Violation because
of violations of North Carolina General Statute 143-215.1 and NPDES
Permit No. NC0005O11 as detailed in the Self -Monitoring Program and
the Permit sections of the attached report. Pursuant to NCGS 143-
215.6A, a civil penalty of not more than ten thousand dollars
($10,000.00) may be assessed against any person who violates or
fails to act in accordance with the terms, conditions, or
requirements of any permit issued pursuant to NCGS 142-215.1.
This letter is also to advise you that the Mooresville
Regional Office of the Division of Water Quality is considering
sending a recommendation for enforcement action to the Director of
the Division. The recommendation concerns the violations of NPDES
permit conditions; specifically for monthly average and daily
maximum limit violations for Flow and Ammonia Nitrogen, and for
failure to submit the alternatives nutrient analysis by the June
30, 1996 due date.
919 North Main Street,
Mooresville, North Carolina 28115
Voice 704-663-1699
FAX [phone]
An Equal opportunity/Affirmative Action Employer
50% recycled/ 10% post -consumer paper

Mr. E.R. Olberding
August 16, 1996
Page Two
If you have an explanation for these violations that you wish
to present, please respond in writing within ten (10) days after
receipt of this Notice. Your explanation will be forwarded to the
Director with the enforcement package for his consideration.
It is requested that a written response also be submitted to
this Office by September 2, 1996 addressing the deficiencies noted
in the OPERATIONS AND MAINTENANCE, RECORDS AND REPORTS and
LABORATORY sections of the inspection report.
Please address your response to the attention of Mr. Rex
Gleason, Water Quality Regional Supervisor, at the letterhead
address. If you have any questions concerning this report or any
other matters, please do not hesitate to call Mr. Gleason or me at
(704) 66-1699.
Sincerely,
h Overcash, P.E.
onal Supervisor
Enclosure
cc: Gaston County Health Department
Division of Air Quality, Mark Hawes
Laboratory Section, Chester Whiting
PB

Transaction Cade
N
Reserved
United States Environmental Protection Agency, Washington, D.C., 20460
NPDES Compliance Inspection Report
NPDES YR/MO,r`DAY
NCO0O5O11 96/7/31
Facility Evaluation Rating
2
BI
N
Data System Coding
Inspection Type
s
Remarks
RA
N
eectice B: Facility Data
Name and Location of Facility Inspected
Carolina By -Products Resources WWTP
US Highway 321 South
Gastonia, Gaston County, North Carolina
Names) of On -Site Representative(s)
Mr. Van. Jones
Title(a)
ORC
Form Approved
OMB No.2040-0003
Approval Expires
7-31-85
Inspector Facility Type
s
Entry Time:
10:05 a.m.
Exit Time/Date:
12:35 p.m.
7/31/96
Permit Effective
Date: 5/1/95
Permit Expiration
Date: 9/30/96
Phone No(s)
[phone]
Nerve, Address of Responsible Official
Mr. E.R. Olberding
Carolina By -Products Resourcea
5533 South York Road
Gastonia , N.C. 28052
Title
Vice Fresident
Phone No.
[phone]
Section C: Areas Evaluated During Inspection (9-Satisfactory, M-Marginal, U-Unsatisfactory, N-Not Eva
Contacted?
No
U Permit S Flow Measurement NA Pretreatment M Operations a Maintenance
M Records/Reports U Laboratory NA Compliance Schedules S Sludge Disposal
S Facility Site Review M Effluent/Receiving Waters M Self -Monitoring Program _ Other
Section D¢ Summe7
See Attached Sheet(e) for Summary
Name(s) and Signature(s) of Inspectors
Patricia Beam
of Findings/Commrvm
Agency/Office/Telephone
NCDRM/MR0/[phone]
Date
6/96
gnature of Reviewer
Taken.
Agency/Office
Regulatory Office Use Only
Date
Noncompliance
Compliance
EPA Form 3560-3 (Rev. 3-85) Previous editions are obsolete

CAROLINA BY-PRODUCTS RESOURCES WWTP NC0005011
Page 2
The facility was last inspected by Mr. Robert Scheller of
this office on August 30, 1995.
PERMIT:
The permit for this facility became effective 5/1/95 and
expires at midnight on 9/30/96. An application for permit
renewal has been filed with this Office. Carolina By -Products
(CBP) has indicated that the facility plans to connect to the
City of Gastonia's Crowders Creek WWTP in the near future.
One of the permit conditions of NPDES Permit #NC0005011 was
the submission of an alternatives nutrient analysis. This study
was to be conducted to indicate the costs associated with meeting
monthly nutrient limits of 1 mg/1 Total Phosphorus and 6 mg/1
Total Nitrogen over a period of time versus the costs associated
with connection of Carolina By -Products discharge to the Crowders
Creek WWTP. The due date for submission of the study was June
30, 1996. Carolina By -Products failed to submit the nutrient
analysis by the required date, nor was a written request for an
extension filed.
FACILITY SITE REVIEW:
The existing facility is a 0.257 MGD wastewater trea
system, located at CBP's Gastonia Division, US Highway 32
Gastonia, Gaston County. The facility consists of the following:
-aerated lagoon
-secondary clarifier
-effluent polishing ponds
-chlorine contact chamber with gas chlorination
-continuous flow measurement
-sludge filter press
All processes exist as described in NPDES Permit No.
NC0005011. Non -contact cooling water is discharged from Outfall
002. The effluent from the treatment works is discharged into
Crowders Creek which is classified Class C waters in the Catawba
River Basin.
OPERATIONS AND MAINTENANCE:
There was a septic odor around the aerated treatment lagoon.
According to the plant manager, the wastewater treatment facility
had been overloaded by an increase in production at the plant
which resulted in the wastewater treatment plant upset. Since
the upset, aeration capability in the lagoon has been increased
to 500-600 HP. The company has also decreased production by
reducing raw material being processed. Hydrogen peroxide is also
to be used to help reduce the odor problem in the lagoon.

CAROLINA BY-PRODUCTS RESOURCES WWTP NC0005011
Page 3
The increased flow to the lagoon due to overproduction and.
recent rainfall has increased the lagoon water depth. There was
very little freeboard at the lowest point of the lagoon dam, and
the ground at this section was saturated. It is suggested that
facilit personnel ins ect the area eriodica l to confirm its
integrity. Action should ala be taken to reduce the
depth so as to main an an adequate and sa
be necessary to adjust the detention ti,m
the lagoon to adjust the water level.
Process control conducted on the lagoon contents include
settleable solids, pH, and dissolved oxygen measurements.
Influent pH can be adjusted if necessary to control the pH level
in the lagoon. Influent ammonia -nitrogen and COD analysis are
performed to track loading to the treatment plant.
At the time of the inspection, solids in the clarifier were
not settling and were apparent in the clarifier effluent. The
plant manager stated that a cationic polymer (Poly -Sep 1146) is
currently being added to the clarifier to aid in settling, which
he indicated had improved since the plant upset. Sludge is
wasted on a daily basis.
Some gasification was observed in both of the polishing
ponds. The polishing ponds (one aerated) are connected in
series. At the time of the inspection, the aerators in the
aerated pond were not in use. The plant manager indicated that
using the aerators could contribute even more to the odor
problems currently being experienced. It may be necessary to
operate the aerators due to the gasification which is already
occurring. It is suggested that old sludg_e collected in the
polishing ponds be removed.
Foam was observed in the chlorine contact basin and in the
catch basin for the discharge line. The plant manager indicated
that the diffuser on the chlorine feed pipe caused the slight
foaming in the chlorine chamber and intensified after air became
entrapped. The foaming was evident in the effluent channel to
the receiving stream; however, it disappeared within a few feet.
The chlorine contact chamber is not checked regularly for solids
build-up. It is suggested that the solids level be checked
periodically, especially after a loss of solids from the system.
RECORDS✓REPORTS:
The Operator in Responsible Charge (ORC) maintains a daily
operator's log documenting time on -site as required by NCAC T15A
.0202(b)(5)(B). Some operational and process control data are
maintained. The maintenance department at Carolina By -Products
is responsible for all maintenance work.

CAROLINA BY-PRODUCTS RESOURCES w "P' NC0005O11
Page 4
Several records were not maintained as required. The flow
meter is calibrated by plant personnel on a quarterly basis;
however, no records are maintained. The flow records consisted.
of totalizer readings from the flotimeeter; however, flowan recorder
strip charts were not used. Analytical requirements, Part II,
not maintained. Pursuant to NPDES permit re q
Section D.6, "...the permittee shall retain records of all
monitoring information, including all calibration and maintenance
records and all original strip cdcopirt es iesoofings for ali reportstrequired
inuous
monitoring instrumentation, [and] p
by this permit, for a period of at least three years from the
date of the sample, measurement, report, or application."
Please be aware that in accordance with
the eNorthoCarolina
Administrative Code T15A: 028 .0506 (c)( )o
information which must also be available for inspection include:
ed
1) The on final labarator eos
ana1vsis cThel se reports
and must
on and
he anaayst"s name.
2) Bench notes and data for sample analyses performed
b the facilit er or not the facility has a.
certified laboratory.
3) Cies o
f OFF MEASUREMENT
Flow is measured by a Stevens float and cable type flow
meter with a totalizer and strip chart recording device. The ORC
indicated that the flow meter is calibrated quarterly; however,
there were no records available to indicate the date of
calibration. The date of calibration and, he ae amthef the erson
erformin the calibration
documentation data.
LABORATORY:
At the time of the inspection laboratory analyses for all
parameters except total nitrogen, total phosphorous, and chronic
toxicity were performed on -site. These parameters are analyzed
by Burlington Laboratory (Certification # 85) in Burlington, N.C.
The on -site laboratory is not certified; therefore, the ORC was
instructed that all certifiable parameters must be analyzed by an
outside laboratory until such time that the Carolina By -Products
Laboratory becomes certified for wastewater analyses. An
initial lab inspection of the CBP Laboratory was performed on
2/7/96 by Mr. Chet Whiting with the Department's Laboratory
ocess con
estin

CAROLINA BY-PRODUCTS RESOURCES WWTP NC0005011
Page 5
Certification group. Refer to Mr. Whiting's inspection report
dated 2/22/96 for comments.
The parameters of pH, dissolved oxygen,
be performed on-site.
1iines Methadsfor
fo anal
r andeWast+swat rers
can be found in the Standard AThe pH meter must be accurate and the
nal sis 18th Edition. and
results reproducible to 0.1 unit,
have
adjustment� ©The+meterbe
equipped with a temperaturecompensation
must be calibrated with two
wbthfarthirdwhich
bufferbracket
forthe
accuracyexpected
sample value, then checked [Reference: Standard Methods 4500 - H+, B (4 2) & )a )]
Calibration information which
sna�edofeanalystneadlibratingincludes,
meter,
ut
is not limited to, date, ,
and standards used for calibration.
The thermometer used for temperature
aifiedanalysis
should
ter be
proper
checked periodically with a NISI
corrections made. Comparison and correction documentation must
be maintained. [Reference: Standard Methods 2550 B (1)). The
dissolved oxygen meter should be calibrated before use as per
manufacturer's instructions. Documentation of meter calibration
must be maintained.
Please be aware that facilities which perform analyses for
three or less parameters listed in Rule .0804 oftTitle
include2H of
i
the North Carolina Administrative Code (NCAC), be exempted
on -site parameters of pH and dissolved oxygen, may
from acquiring certification for these parameters. A written
e uest for the certification exewil on must
be filed
onwith the
case b
Late Labvratdr�r. Such re uests
case basis.
A portable composite sampler
used
lerfor
withsample
the samplecollection.
An ice block is place in a styrofoam cooler
however, the
bottle at the beginning of the sampling P
sample temperature is not checked for verification of maintaining
samples at 4°C. The temperature of the sam le at the end of the
cdmpositine t eridd must be checked and recorded.
Samples are not collected proportional to flow. In
accordance with NPDEspermit
be cvllectedrequirements,
flowPart
prvportidnalSection
basis.
composite samples mut
If the effluent flow varies by no more than 15%, samples may be
collected by constant flow/constant time method. Prior approval
from the Division of Water ualit must be obtained
a 24 hour period S through
and
temperature will

CAROLINA BY-PRODUCTS RESOURCES WWTP NC0005011
Page 6
It was indicated that unchlorinated effluent samples are
collected for BOD analysis. Please be aware the North Carolina
Administrative Code (NCAC) T15A: 02B .0503 (12) refers to
effluent being "wastewater discharged following all treatment.
processes from a water pollution control facility..."L_thereforeL
all effluent sam les must be collected after all treatment
process, includinq chlorination.
SELF -MONITORING PROGRAM:
Self -monitoring data was evaluated for June 1995 through May
1996. Several discharge limitation violations were noted.
Ammonia -Nitrogen Monthly Average Limit: 140 lbs/day
January 1996
February 1996
March 1996
April 1996
Flow Monthly Average Limit:
December 1995
February 1996
March 1996
*NOV issued
Ammonia -Nitrogen Daily Maximum Limit:
January 22, 1996
February 1, 1996
March 6, 1996
March 20, 1996
March 27, 1996
April 4, 1996
April 19,1996
SLUDGE DISPOSAL:
232.8
145.0
429.0
273.0
lbs/day*
lbs/day*
lbs/day*
lbs/day*
0.257 MGD
0.258
0.275
0.345
MGD
MGD
MGD*
280 lbs/day
327.0 lbs/day
294.7 lbs/day
298.0 lbs/day
867.0 lbs/day
444.8 lbs/day
415.0 lbs/day
315.0 lbs/day
Sludge from the filter press is recycled to the rendering
plant.
EFFLUENT/RECEIVING WATERS:
At the time of the inspection, the effluent appeared brown
with some foam present. The effluent was evaluated on -site for
the following parameters:
-Temperature
-Dissolved Oxygen
-pH
27.8°C
1.7 mg/1
7.97 s.u.

CAROLINA Y-PR DUCPS REROORC
Page
The effluent flows through an effluent channel to the
receiving stream; however! the low dissolved oxygen content of
the effluent still has the potential to negatively impact the
receiving stream. The' effluent channel to the receiving stream
is a discernable confined conveyance which is contained on the
e ittee's property and consists of only the Carolina
Products discharge. The receiving stream was not evaluated
during the inspection due to difficult access:.

State of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr., Governor
Jonathan B, Howes, Secretary
June 5, 1996
Mr. Tan M. Jones
CBP Resources
5533 S. York Road
Gastonia, NC 28052.
SUBJECT: Wastewater Laboratory Certification
Dear Mr. Jones..
State Regulation NCAC 2H-T .0800 requires all Class I, and II
WWTP Laboratories submit an application by July 1, 1995, or within
ninety days of a request by the State Laboratory. Such a request
was sent in the letter dated January 30, 1995.
The application for the CEP Resources WW Laboratory has been
received, and reviewed. The initial laboratory .inspectionhas been
performed, and the report indicating deviations to be corrected
prior to certification was mailed February 22, 1996. Tn your letter
dated March 12, 1996, you requested an extension until May 22, 1996
to address the deviations cited in the inspection report. To this
date a response to the inspection report has not been received.
In the initial inspection of the laboratory, it was noted that
several certifiable parameters included in the monitoring
requirements of discharge permit NC000591.1 were being analyzed
without certification for the parameters.
Regulation .0804 contains a listing of certifiable parameters.
Your facility must be certified. for all certifiable parameters
included in the monitoring requirements of your NPDES Permit and/or
pretreatment program, if the parameter analyses are performed in
your laboratory. If you choose, any or all of your State required
monitoring analyses may be performed by a. certified commercial
laboratory. We have allowed ample time for your laboratory to meet
certification requirements in accordance with 1SA NCAC 2H .0810 (d)
(4). Effective July 1, 1996, we request that your samples be
analyzed in a certified laboratory. Please, provide this office with,
the name of the laboratory you will use.
919 North Main Street,
Mooresville, North Carolina 281 15
Voice 704-663-1699
FAX [phone]
An Equal Opportunity/Affirmative Action Employer
50% recycled/ 10% post -consumer paper

DEP Resources
Page Two
June 5, 1996
If You have any questions, or need additional information
contact us at 704 663 -1699. ewe, 232.
CC: William B. Edwards, Jr,
Norm Good
Keith Overcash'
S3.hcerely
)
Chester Whii4p45.
DEM Lab Certification

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Environmental.Management
919 North Main Street Mooresville, North Carolina 28115
June 17, 1996
VAN M. JONES
CBP RESOURCES - GASTONIA DIV.
5533 SOUTH YORK ROAD
GASTONIA NC 28052
SUBJECT: Notice of Violation - Effluent Limitations
NPDES No. NC0005O11
CBP RESOURCES - GASTONIA DIV.
GASTON County
Dear VAN M. JONES:
Review of subject self -monitor
of April, 1996 revealed violation(
parameter(s):
Pipe Parameter
ing report for the month
of the following
Reported
Value/Unit
Limits
Value/Type/Unit
001 00610 NH3-N 273.00 LBS/DA 140.00 FIN LBS/DA
Remedial actions, if not already implemented, should be
taken to correct the problem(s). The Division of Environmental.
Management may pursue enforcement actions for this and any
additional violations of State Law. If you have questions or if
you need assistance, pitease call D. Rex Gleason, Regional Water
Quality Supervisor, at 704/663-1699.
Sincerely,
B. lith Overcash
Regional Supervisor
cc: Central Files
GKBDEX96/BL

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Environmental Management
919 North Main Street Mooresville, North Carolina 28115
May 13, 1996
VAN M. JONES
CBP RESOURCES - GASTONIA DIV.
5533 SOUTH YORK ROAD
GASTONIA NC 28052
SUBJECT. Notice of Violation - Effluent Limitations
NPDES No. NC0005O11
CBP RESOURCES - GASTONIA DIV.
GASTON County
Dear VAN M. JONES:
Review of subject self -monitoring report for the month
of March, 1996 revealed violation(s) of the following
parameter(s):
Pipe Parameter
001 50050 Q/MGD
001 00610 NH3-N
Reported Limits
Value/Unit Value/Type/Unit
.3450 MGD .2570 FIN MGD
429.00 LBS/DA 140.00 FIN LBS/DA
Remedial actions, if not already
taken to correct the problem(s). The
Management may pursue enforcement act
additional violations of State Law.
you need assistance, please call D. R
Quality Supervisor, at 704/663-1699.
cc: Central Files
GKBDEX96/BL
implemented, should be
Division of Environmental
ons for this and any
f you have questions or if
x Gleason, Regional Water
Sincerely,
B.�eith Overcash
Re .onal Supervisor

REc4
Gastonia Division
CBP Resources, Inc.
G.
THE OF OUR BUSINESS.
Mr. Ken Eagleson, Assistant Water Quality Chief
Environmental Sciences Branch.
NC Division of Environmental Management
4401 Reedy Creek Rd
Raleigh, NC 27607-6445
Subject: Effluent Toxicity Report
January,1996 Report
CBP Resources
Gaston County, NC
Dear Mr. Eagleson:
With regard to your notification that you had not received this facility's subject
document, please find enclosed a copy ofthis report. The original was mailed to you in
February, 1996..
Should there be any questions, please let me know.
Since ely,.
Van M. Jo
Environmental Manager
cc: Mr. Rex Gleason
5533 5. York Rd, • Gastonia, NC 28052 • 704-864.9941 • Fax # [phone] • Direct Dal Number:

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Environmental Management
North Main Street Mooresville, North Carolina 28115
April 8, 1996
VAN M. JONES
CBP RESOURCES - GASTONIA DIV.
5533 SOUTH YORK ROAD
GASTONIA NC 28052
SUBJECT: Notice of Violation - Effluent Limitations
NPDES No. NC0005011
CBP RESOURCES - GASTONIA DIV.
GASTON County
Dear VAN M. JONES:
Review of subject self -monitoring report for the, month
of January, 1996 revealed violation(s) of the following
parameter(s):.
Pipe Parameter
Reported Limits
Value/Unit Value/Type/Unit
001 00610 NH3-N 232.80 LBS/DA 140.00 FIN LBS/DA
Remedial actions, if not already implemented, should be
taken to correct the problem(s). The Division of Environmental
Management may pursue enforcement actions for this and any
additional violations of State Law. If you havequestions or if
you need assistance, pY^.9se call D. Rex Gleason, Regional Water
Quality Supervisor, at 704/663-1699.
Sincerely,
h Overcash
Reg anal Supervisor
cc: Central Files
GKBDEX96/BL

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
Division of Environmental Management
919 North Main Street Mooresville, North Carolina 28115
March 18, 1996
VAN M. JONES
CBP RESOURCES
5533 S. YORK HIGHWAY
GASTONIA NC 28052
SUBJECT: Notice of Violation - Effluent Limitations
NPDES No. NC000SO11
CBP RESOURCES
GASTON County
Dear VAN M. JONES:
Review of subject self -monitoring report for the month
of December, 1995 revealed violation(s) of the following
parameter(s):
Pipe Parameter
001 50050 Q/MGD
Reported
Value/Unit
Limits
Value/Type/Unit
.2580 MGD .2570 FIN MGD
Remedial actions, if not already implemented, should be
taken to correct the problem(s), The Division of Environmental
Management may pursue enforcement actions for this and any
additional violations of State Law. If you have questions or if
you need assistance, plse call D. Rex Gleason, Regional Water
Quality Supervisor, at 704/663-1699.
Sincerely,
eith Overcash
eiona1 Supervisor
cc: Central Files
GKBDEX96/BL

MEMO
TO:
THRU:
FROM:
SUBJECT:
DIVISION OF ENVIRONMENT MANAGEMENT
August 25, 1995
Jay Lucas
Ruth Swanek
Steve Bevington
Carla Sanderson
Jacquelyn M. Nowell
Modification of NH3 Limit for CBP Resources
NPDES Permit NO. NC0005011
Gaston County
The Instream Assessinent Unit has reviewed the memo concerning elimination or
modification of the NH3 concentration limit for the subject facility. A review of the
wasteload allocation file shows that the addition of the NI-I3 concentration limits of 65 mg/i
as monthly average and 131 mg/I as daily maximum are based on oxygen consumption and
were applied in the QUAL2E model developed for the Crowders Creek basin. The model
results indicated that with the cumulative affect of other dischargers in Crowders Creek, the
concentration limits for CBP will provide additional protection of dissolved oxygen in the
receiving stream. (The ammonia toxicity limits of 26 mg/1(summer) and 80 mg/1 (winter)
were also evaluated and are more stringent than the oxygen consuming concentration
limits.)
rd,C. DEPT. OF
l ��iM >^ T, HEALTH,
..TL, 1RAL RES(')UR4U:S
SEp 8 1995
DIV1510 6F E,Eiv'IIION "ENTR1 hifiNiatIERT
ORESitttE itErAPIAL OFFICE
If CBP has indicated that they would connect to the Gastonia- Crowders Creek
WWTP if the NH3 concentration limits are removed, then it is recommended that the
concentration limits be rescinded, ifGB-Fagrees-to connect -to -Gastonia. This is an option
that should be taken, because any reduction of direct discharge wasteflow into Crowders
Creek can only improve the quality of the stream. However, the Division should include a
condition that if the connection to the regional plant is not made, then the NH3
concentration limits will be reapplied to the NPDES permit.
Please contact me if there are any additional questions.
Mike Parker, MR0
Central. Files
LdLA F'ie

MICHAEL.F.EASLEY
ATTORNEYGENERAL
SUITE 203
11 NORTH MARKET STREET
ASHEVILLE, N. C. 28801
ME ORAN1MJM --
TO: A. Preston Howard
Director, Division of Environmental Management
FROM: Susanna P. Sumpter(/3
Assistant Attorney General
DATE: September 25, 1995
RE: CPB Resources, Inc. v. DEHNR
OAH File No: 95 EHR 0480
N,Co DEP"I'. t;'*.
ENVIRONMENT,
& NATURAL t:C3°;o! "ttf'°;i^:;
SEP 2 9 1995
WESTERN OFFICE
PHONE [phone]
FAX '704/251-6338
I am sending to you copies of the consent order entered by the Administrative Law Judge in the
above -referenced contested case, The hearing in this matter will be held the week of November 6, 1995
in Charlotte, North Carolina.
The following persons may be called to
y at the hearing:
A. Preston Howard
Director, Division of Environmental Management
Coleen Sullins
Head, Permits and Engineering Group
Jay Lucas
Permits and. Engineering Group
Jackie Nowell
Technical Support Group
Rex Gleason
Regional. Water Quality Supervisor
Michael Parker
Mooresville Regional Office
An Equal Opportunity / Affirmative Action Employer

A. Preston Ho
Page Two
September 25„ 995
Please le
e know " lediately if any of dxe per listed above ca of be available On the date proposed..
Thank you.
SPS/Igg
Enclosure
xci Coleen Alin
Carla Sanderson
Rex Gleason (MRCS)

STATE OF NORTH CAROLINA
COUNTY OF GASTON
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
95 EHR 0480
CPB RESOURCES, INC., GASTONIA DIVISION
Petitioner
v.
NORTH CAROLINA DIVISION OF ENVIRONMENTAL
MANAGEMENT
Respondent
motion f
reasons
part.
owing:
otter came on
continuance,
or hear
ich mot.
9
n
CONS
ORDER
based upon the Petitioner
is made fo the following
The parties believe this matter may be resolved;
such resolution, requires the input of the City o
which .i not a party to this proceeding. The pa:
time to meet with the City of Gastonia.
further represent to the Administrative Law Juc
owever,
Gastonia
ies need
ge the
The Respondent consents to the motion for continuance and that
the grounds for the continuance constitute: good cause pursuant
to Rule'26 NCAC 03 ..0118.
2 The parties agree to have
p.m. on October 20, 1995.
The parties agree to have
1995.
4. The parties agree to submi
date of the hearing.
5. The parties
of November
will in all
all dispositive
ed by 5:00
all discovery completed by October 13,
a Prehearing Order on or before the
agree that the hearing
6, 1995 in Charlotte,
respects be ready for
WHEREFORE, IT IS HEREBY ORDERED by
ood cause shown that:
The motion to continue is AL D.
ill be continued to the week
rth Carolina and the case
iai during that week.
consent of the parties and

CONS
The hearina in this matter
the weekcatNovember 6, 1995, , in h r1 tt ,, North Carolina,with
Notice of Hearing to to11 w.
NTH": TO:
eiicner't.orney
Enter a by consent .his te
continued to the docket set for

A copy of t e foregoing was mailed to:
Ramona C. O'Bryant
Smith Helms Mulliss & Moore
Attorneys at Law
PO Box 21927
Greensboro NC 27420
Attorney for Petitioner
St/eel-lea P. Sumpter
Assistant Attorney General
NC Department of Justice
11 North Matker St
Suite 203
Asheville NC 28801
Attorney for Respondent
phis the d Y ef
Orrice at Adminmstrative Hearings
PO Drawer 27447
Raleigh NO 27611-7447
919i/33-2698

RECYCLUNG.T14E NATURE OF OUR BUST N'ESS.
May 4, 1995
Office of Administrative Hearings
PO Drawer 27447
Raleigh, NC 27611-7447
Subject: Petition For Contested Case
NPDES Permit #NC0005011
CBP Resources, Inc.
Gastonia, NC
Dear Sir Or Madam:
Gastonia Division
CBP Resources, Inc.
Enclosed please find the original and two copies of the subject petition. Please
file -stamp one of the copies and return to me for my records.
Thank you for your attention to this matter.
Sincerely,
an M.'Jnes
Plant Manager
VJ/kb
cc: Mr. Jonathan B. Howes (Attn: Richard Whisnant)
Mr. A. Preston Howard
Mr, Mike Parker
5533 S. York Rd, • Gastonia. NC 28052 • 704-864-9941 • Fax # [phone] • direct Dial Number:

PPPr"`
STATE OF NORTH CAROLINA
COUNTY OF (I) GASTON
PLEASE FRIN ` CLEARLY OR E
IN "ItII OFFICE OF
STRATWVE HEARINGS
(2) CPB RESOURCE'S. INC.. GAS TONIA DIVISION.
Petitioner,
(Your Name)
v.
(3) ;NORTH CA OLINA DIVISION OF
_ENVIRONMENTAL MANAGEMENT.
Respondent.
(The State Agency or Board about which you are
complaining)
PETITION
FOR A
CONTESTED CASE HEARING
I hereby ask for a contested case hearing as provided for by G.S. 150E-23 because the,
(4) ._ North Carotin&Divisgon of Environnaentad Martagement has:
(name cf agency)
(Briefly state facts showing how you believe you have been harmed by the state agency or board.)
issued NPDES Permit No. NC0005Q11 with ammonia concentrations that )vill greatly restrict the operation of CBP's facility
with no measurable benefit to the receiving stream. DEM also has indicated that more stringent limits for phosporus and
nitrogen will be required in the future. The permit requires that a cost analysis be conducted even though DEM has made
it clear that this discharge will be eliminated from. Crowder Creek and that CBP will have to connect to the POTW.
(if more space is needed, use additional sheers and attach)
(5) (Check all that apply) Because of these facts, the agency has:
**
A deprived me of property;
ordered me to pay a fine or civil penalty;
tt otherwise substantially prejudiced my
rights; and based on these facts the agency
has exceeded its authority or jurisdiction;
************.**************************************************Irk**'********************************-***
(6) Date: May.3 1995
(8) Print your address: CBP Rcsou
(9) Print your name: Van Jones
(10) Your signature:
nia Divisio
x, acted erroneously;
failed to use proper procedure;
at acted arbitrarily or capriciously; or
failed to act as required by law or rule.
(7) Your telephone number: [phone]
5533 S. York Road. Gastonia. NC 28052
You must mail or deliver a COPY to the State Agency named on line (3) of this form. Please indicate below.
CERTIFICATE OF SERVICE
I eertify that this Petition has been served on the State Agency named below by depositing a copy of it with the United
States Postal Service with sufficient postage OR by delivering it to the named agency.
Served on:
(11) Jonathan B. Howes (Attn: I
and A. Preston Howard J
(name)
61 ..:' Salisbury Street. Raleigh. NC 276
.E
(14) This the 3 day of May 1995.
(15)
(12) NCDEHN
(address)
n of Environ
(agency)
anagemcnt
When you have completed
rrn you 'MUST mail or deliver the ORIGINAL and one COPY to
trative Hearings, P.O. Drawer 27447, Raleigh, NC 27611-7447.
Office of Adminis-
H-06 (11/91)

"Pof North Carolina
partment of Environment,
r
and Natural Resources
Mooresville Regional Office
James B. Hunt Jr„ Governor
Jonathan B. Howes, Secretary
Linda. Diane Long: Regional Manager
DIVISION OF EB
IRONMENTAL MANAGEMENT
September 22, 1995
Mr. E.R. Olberding, Vice President
Carolina By -Products Resources
5533 S. York Road
Gastonia, NC 28052
Subject:
Compliance Evaluation
Inspection
Carolina By -Products WWTP
NPDES Permit No. NC0005O11
Gaston County, NC
Dear Mr. Olberding:
Enclosed is a copy of the Compliance Evaluation Inspection
Report for the inspection conducted at the subject facility on
August 30, 1995 by Mr. Roberto L. Scheller of this Office.
The report should be self-explanatory; however, should you
have any questions concerning this report, please do not hesitate
to contact Mr. Scheller or me at [phone].
Sincerely,
;VL, Q V\
D. Rex Gleason, P.
Water Quality Regional, Supervisor
Enclosure
cc: Gaston County Health Department
RS
919 North Main Street. Mooresville, North Carolina 28115 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Transaction Code
N
Environmental :Protection Agency, Washington, D.C., 20460
NPDES Compliance Inspection Report
A: National Data Syetaaaz Ct'!+'1lug
NPDF YR/1 7/DAY
NC0005O11 95/08/30
For Approved
OMR No.2040-0003
Approval Expires
7-31-85
Inspection Type Inspector facility Type
c S 2
R+»*ks
Facility Eva ltlati{8n Rating
4
SI
N
QA
N
Name and Location of Facility Inspected
Carolina By -Products Resources
US Hwy 321 South
Gastonia, Gaston County, NC
Entry Time:
1©:1© a.
95
Exit Time/Date:
12:00
n
ate: 9/30/96
of On -Site Representative(s)
Van .Tones
Title(s)
Plant. Manager
[phone]
Naffs Adeiresa oaf'Reaponaible Official
olberding
Carolina By -Products Resources
5533 S. York Road
Gastonia, NC 28052
Title
Vice President
hone No.
70464-9941
Section C: Areas Evaluated Daring Insn (S-Satisfactory, t+X-Marginal, U-Unsatisfac
Contacted?
No
t S Flow Measurement N Pretreatment
da/Reports N Laboratory NA Compliance Schedules
ity Site Review S Effluent/Receiving Waters S Se1f-Monitoring Program
Operations & Mintonanc
Sludge Disposal
Other
D: S of FindingaI
Attached Sheet(s) for Summary
and Signature(s) of Inspectors
berto L. Scheller
Agency/Office/Telephone
NCDEM/MR0/[phone]
8/30/95
of Reviewer
g
Date.
Offic
Action Taken
EPA Form 3566-3 (Rev. 3-85) Previous editions are obsolete
Noncompliance
Compliance

CBP Resources WWTP
Page Two
This facility was last inspected by Mr. Joe Crabb of this
Office on June 29, 1994.
PERMIT:
The permit for the subject facility was issued on April 7,
1995 and expires at midnight on September 30, 1996.
Please be advised that application for permit renewal
shall be accomplished by filling out the appropriate application
form at least 180 days prior to expiration of the permit. Renewal
request received less than 180 days prior to permit expiration will
be required to pay the new application/modification/late renewal
fee rather than the timely renewal without modification fee.
FACILITY SITE REVIEW
The existing facility is a 0.257 MGD wastewater treatment
system consisting of:
- screening/mechanical grease traps
- primary treatment basin with mechanical aeration
- secondary clarifier
(3) polishing ponds
chlorine contact chamber
- continuous flow measurement
- sludge dewatering facilities (filter press)
The final effluent is discharged into Crowders Creek via
outfall line 001.
Wastewater discharge from outfall 002 consists of non -contact
cooling water.
OPERATIONS AN
All process units of the treatment plant were inspected. The
following observations were made during the inspection:
1. The facility appeared to be in good operational condition at
the time of the inspection.
2. The process control program consists of settlometer, COD, NH3
temperature, total residual solids and pH testing.
3. Maintenance records, process control data, and other plant
records are kept at the facility.

CEP Resources WWTP
Page Three
RECORDS AND REPORTS:
1. Monitoring records and self -monitoring reports (DMR's) are
maintained as required by NPDES Permit. Copies were on file in the
facility office and were readily available.
2. A cursory review found no discrepancies in reported data and
laboratory analytical reports.
SELF-MONIT©RING PROGRAM:
1. Self -monitoring reports were reviewed for the period July,
1994 through June, 1995, inclusive.
2. The subject facility had no effluent limit violations during
the review period.
3. All parameters are being monitored at their correct
frequency.
LABORATORY:
1. The subject facility has an on -site laboratory (certification
pending) that performs compliance monitoring analyses for pH, D.O.,
temperature, TRC, conductivity, BOD, TSS, NH3, and fecal conform.
2. The application for laboratory certification was received on
March 29, 1995.
3. Chronic toxicity testing is performed by Burlington Research,
Inc. (certification # 85) in Burlington, North Carolina.
FLOW MEASUREMENT`:
1. Influent flow is measured by a continuous recording flow
meter. The flow meter appeared to be operating properly at the
time of the inspection.
2. The flow meter is calibrated monthly by the on -site
maintenance personnel.
EFFLUENT/RECEIVING STREAM:
1. Effluent was evaluated during the inspection of the subject
facility and the results are as follows:

Page Four
Effluent was brawn in el with visible amounts
suspended solids
Temperature 26 degrees el i
- Dissolved Oxygen (DO) 1.1 mgil
pH 7.92 s.u.
The receiving stream was not evaluated dur ng this inspection.
SL GE DISPOSAL:
Sludge is dewtee: and eturned back
for recycling.
the
aw material pit

f North Carolina
artment of Environment,
ealth and Natural Resources
Division of Environmental Management
James B, Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr„ PE„ Director
Mr. Gene Olberding
CBP Resources
5533 S. York Highway
Gastonia, NC 28052
SUBJECT: Waste
Dear Mr. Olberding:
e
February 6, 1995
aboratory Certification
'' r\7'R4kNafeu .z1 a;
Ea
The November 1992, amendments to the Wastewater/Groundwater Laboratory
Certification Rules required all wastewater laboratories to be certified. The Rules
delayed certification of laboratories for Class I and II Wastewater Treatment Plants
until July 1, 1995, or within ninety days of a request by the State Laboratory.
According to our records, your facility is subject to these Rules.
Enclosed, for your use, are copies of the Certification Regulation (NCAC 2H
.0800) and an application for certification. Also, enclosed are selected pages from
the October 26, 1984, June 30, 1986, October 9, 1991, and January 31, 1994,
Federal Registers containing a listing of approved analytical procedures.
Regulation .0804 contains a listing of certifiable parameters. The certification
must include all certifiable parameters included in the monitoring requirements of your
NPDES Permit if they are performed in your laboratory. The first step toward
acquiring certification is to complete and return the enclosed application form. If
some of your State required monitoring analyses are performed by a commercial or
other certified laboratory those parameters are not required to be included in the
request for certification.
In the application for certification, each laboratory must designate a laboratory
supervisor and laboratory manager. Part .0805 (A) (3) (B) and (C) of the regulation
sets forth the requirements; however, all existing supervisors will be accepted. The
person designated as laboratory supervisor should be the person responsible for the
daily operation of the laboratory and any data reported. Following receipt of the
application, all correspondence will be directed to the laboratory supervisor unless we
are given other instructions.
Prior to certification, each laboratory will be billed the appropriate fees as set
forth in Section .0806 of the Regulations. Do not send payment for fees with the
certification application.
Laboratory Section
4405 Reedy Creek Road, Raleigh, North Carolina 27607-6445 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 1 O% post -consumer paper

By regulation tion you are to complete are + t rrr the nclosapplication to this
office within ninety ay ., if ya 1r have questions n or r "end additional information,
contact Norman Good or me 1'
Sincerely,
Lahore y Section
Enclosure
cc: Norman Good
Chet Whiting
Mooresville Regiort l0 cy

RE C.I_lNu
R.B SINI:
January 26, 1995
UN VIRONa6I,vr, I- L,\LTHcBP Reso
N\TC`1,.. L it I'. p. .f;aars;
JAN 30 1995
gOfRES iLLE R10I
Mr, D. Rex Gleason, P. E.
Water Quality Regional Supervisor
NC Division of Environmental Management
919 N Main Street
Mooresville, NC 28115
Subject Effluent Self -Monitoring
Carolina & Southern Processing
Gaston County, NC
Dear Mr. Gleason:
This letter is in reference to this facility's self -monitoring report for December,
1994,
The first item is in regard to the pH values for the 12th and 13th on the effluent
form. I do not feel these are representative, This appears to be the result of our
technician's failure to ensure proper calibration. Our meters are on a calibration
schedule; however, this was simply not adhered to.
Second, due to an oversight, tests for BOD5, NH3, TSS, Oil and Grease and
Fecal Coliform were performed once rather than twice as required.
We regret this occurred and will strive to prevent reoccurrence.
Sincerely,
/
Van M. Jones
Plant Manager
VJ/kb
5533 S. Yj Rd.. •Ca�str pia NC 28052 • 7t)4-864-9941 • Fax # 704- a1-9252 • Direct Dial Number: